estates. In relation to testate succession, a widow may where she has not been adequately provided for under a will, make application to the Court for such provision. 244 In case of an intestate, the Act provides for principles of distribution of property which particularly state that a spouse of the deceased is entitle to inherit any property of the deceased. In Section 3, the Act has significantly narrowed down primary beneficiaries to the deceased estate to immediate family, namely spouse and children. This has helped in strengthening protection of women’s property as an economic resource. 245 Where the deceased was in a polygamous union, the Act protects the surviving widows in that each widow living in a different locality shall be entitled to a share of the property of the intestate in their locality in accordance with the Act. No widow and her children shall have a claim to any share of the property of the intestate in the locality where another widow lives. If the intestate left more than one widow surviving him all living in the same locality, each widow and her children by the intestate shall be entitled to a share of the property of the intestate proportionate to their contribution. 246 Further to that, customary law which perpetrated property grabbing in the absence of a will no longer applies in the distribution of deceased estates. Instead, distribution of property follows the principles of fairness set out in the Act. This ensures the protection of widows from property grabbing. The Act also declares any property grabbing by a deceased spouse’s relatives to be a criminal act and subject to criminal prosecution. 247 Section 13 (j) of the Constitution provides that the state shall adopt policies and legislation to respect and support the elderly through the provision of community services and to encourage participation in the life of the community. In 2016 Malawi adopted a National Policy for Older Persons. The Policy establishes Community Elderly Committees which will be responsible for implementation of the policy in liaison with all other stakeholders under the coordination of the Ministry of Gender. For easy liaison, there will be a gender sensitive and inclusive representation in the committee consisting of not more than 10 older persons. One of the strategies under the Policy includes designing and implementation of old age gender sensitive and inclusive programmes. 101