SCROLL NO.–51 ALIENATION- UNDER HINDU LAW A Project Report submitted to University Five Year Law College Jaipur Paper-V, Family Law-II Under supervision of: Prof. Alpana Sharma Faculty, Semester University Five Year Law College University of Rajasthan Jaipur Submitted by: Shruti Jain Student of 5th UFYLC, Jaipur UNIVERSITY FIVE YEAR LAW COLLEGE UNIVERSITY OF RAJASTHAN JAIPUR February, 2012 i TABLE OF CONTENTS Scroll No. –51......................................................................................................................i UNIVERSITY FIVE YEAR LAW COLLEGE.................................................................i a) UNIVERSITY OF RAJASTHAN................................................................................i INTRODUCTION..............................................................................................................1 The aim of this Project work is to determine and analyze ILO (International Labour Organization) Conventions with Regards to Protection to Women Labour......................2 ALIENTION UNDER DAYABHAGA SCHOOL...........................................................2 Father as an Alienator.........................................................................................................3 Karta’s powers of Alienation.............................................................................................4 b) Hunooman Persaud v. Mussmat Babooee...................................................................4 Legal Necessity...................................................................................................................6 Indispensable Duties...........................................................................................................7 Right of Coparcener to Alienate his Share.........................................................................7 Legal Recourse in case of Invalid Alienation....................................................................9 Burden of Proof................................................................................................................10 Alienee’s Rights and Remedies........................................................................................11 CONCLUSION ................................................................................................................13 bibliography........................................................................................................................v Prof. Alpana Sharma Faculty University Five Year Law College University of Rajasthan, Jaipur CERTIFICATE ii encouragement. She has written the project report entitled “Alienation.It is to certify that Shruti Jain is a student of 5th Semester of University Five Year Law College. It is further certified that candidate has made an appreciable attempt on subject mentioned above. Prof. I express myself in depth respect and gratitude to all of them. Alpana Sharma Supervisor ACKNOWLEDGEMENT I am happy to disclose the individuals. who spend their valuable time from their busy schedule for encouraging me in completion of the project. Their fruitful guidance. support and supervision had given me a positive dimension for initiation and completion of this iii .Under Hindu Law” under my guidance and supervision. Jaipur. project successfully. the project present on “Theory of Production: a study” has been carried out. University of Rajasthan iv . I also express my sincere thanks and gratitude to my friends all other for being extremely helpful and coordination while carrying out this project. It gives me utmost pleasure and proud privileges to acknowledgment my sincere sense of gratitude to Prof.Lecturer (Family Law-II) under whose inspiring guidance and kind supervision. Shruti Jain 5th Semester University Five Year Law College. Alpana Sharma. . p. The distinguishing feature of this power is that it was traditionally given only to the father or the karta and that.THE HINDU CODE. this is why the ancient texts have specified several conditions which alone would justify such acts of the manager. The effort has been made to list all the varying viewpoint and critically analyse them in the light of old traditions and newfound legal principles. but the power itself is near autocratic as it allows them to sell. The lack of any codified law as well the changing face of the commercial transactions a joint family enters into these days have created many situations where even the jurists have still not agreed upon the settled law and this constant situation of flux makes alienation a very interesting study.1996. . coparcener or the sole surviving coparcener of a part or the whole of the joint family property by any act or omission.INTRODUCTION Alienation can be defined as “it includes as any disposal by the father. These conditions have changed over the centuries to keep in pace with the changing conditions and the ancient rules have been modified by the Privy Council in accordance with the principles of equity.6th ed. 1.586. Hari Singh Gour. 1 . Alienation is of vast practical utility as it gives a way of using the joint family property for the common use of the family and it is a classic example of the unique position of the hindu joint family which is always ready to help its members in times of need and who work together for common benefit.1 RESEARCH METHODOLOGY The researcher has used doctrinal method and relied only upon secondary sources of data to prepare this project. justice and good conscience. intended to take part in present or future”1 Thus it can be said that alienation has a very wide scope and application. voluntary or involuntary. karta. gift or mortgage the whole joint family property without the consent of any coparcener. Motee Lal Mitterjeet 6 SD 73 (85) . situated in the province of Bengal. . by will. father is provided with the absolute powers regarding alienation. father doesn’t need the consent of his sons for the purpose of alienation. consistently with the decisions of the court. Kishenkunkar. prevent. and the customs and usages of the people. and that the consent of the sons. i. the Supreme Court of Bengal referring to the judges of Sudder Dewanny returned the following certificate. (1812) 2 SD 42 (52). who has sons. without their consent immovable ancestral property.2 the Sudder court held that the gift by a father of his whole estate to a younger son.3 2 3 .1. he can alienate separate as well as ancestral property. Jugomohan v. 90. Later in 1831. he can. give or pledge. Morton. during the life of the elder was valid though immoral. As the sons don’t get a right over the property by birth under Dayabhaga school. however the gift of whole ancestral landed property was forbidden. we are unanimously of opinion that the only doctrine that can be held by the Sudder Dewanny Adalat. is that a Hindu. In Ramkoomar v. On mature consideration of the points referred to us. ALIENTION UNDER DAYABHAGA SCHOOL Under Dayabhaga school. including movable and immovable on his wish. Neemoo. which empowers him to alienate the property even when there is no moral justifications. alter or affect their succession to such property. can sell. Father enjoys an absolute power.2 HYPOTHESIS The aim of this Project work is to determine and analyze ILO (International Labour Organization) Conventions with Regards to Protection to Women Labour.e. A classic example of such a gift came up before the Privy Council in the case of Bachoo v.supra n. Even in the case of the coparcener.2000. however the rule in this case is that the value of the property gifted must be very small in comparison to the entire movable property.The two cases are dealt with belowGifts of love and affection – The father can make a gift of reasonable amount of the ancestral movable property out of love and affection4 to the family members who are not entitled to any share at the time of the partition.supra n.In this a gift made to the daughter of Rs.HINDU LAW. 3 p. Mulla.supra n. (1924) 51 IA 129. 6 . Mankore Bai7 . he loses his interest in the joint property which he cannot subsequently alienate.Father as an Alienator A father possesses more power even than karta as there are situations in which only the father has the authority to make alienation. for unethical or immoral purposes. (1920)43 Mad 824. In the case of Subbarami v.797. Mangla Prasad. 2003. Father’s Debt-Father can alienate family property to pay his personal debts if the following two conditions are fulfilled1 The debt is antecedent .HINDU LAW AND USAGE. (1907)34 IA 107. .331.p.332. wife or even the son. 2 p.5 Thus the gift of affection may be made to the daughter.8 4 5 . 8 . Rammamma 6 an important principle was laid down that such gifts cannot be made by a will.636.p. The above two rules though derived from ancient Mitakshara text was also laid down in the case of Brij Narain v. .15th ed. since as soon as a coparcener dies.17th ed. Mayne.318. 2 The debt should not be Avyavaharik i.20000 was held to be valid as the total value of the estate was 10-15 lakhs.e. 1 p. 7 . For the benefit of the estate. a limited and qualified power. The modern law of alienation was settled to a large extent in the landmark judgment of Hindu Succession Act. The Privy Council in its decision went on to lay many other principles which are still relevant in deciding cases on invalid alienation: The power of the manager for an infant heir to charge an estate not his own is under the Hindu Law. 1956. Their lordships think that the lender is bound to inquire into the necessities for the loan and to satisfy himself as well as he can with reference to the parties with whom he is dealing that the manager is acting in a particular instance for the benefit of the estate.e. Hunooman Persaud v.the bona fide lender is not affected by the precedent mismanagement of the estate. .Karta’s powers of Alienation The modern law of alienation is completely based on the ancient texts with little or no deviation from the basic rules given there. Dharmarthe. Here three conditions were stated in which the alienation would be valid:1. or the benefit to be conferred upon it in the particular instance is the thing to be regarded …. The actual pressure on the estate. 3 p.supra n. For religious purposes i.370. It can only be exercised rightly in the case of need or for the benefit of the estate. the danger to be averted. father or karta. However they think that if he does so inquire and acts 9 . However where in particular instance. Corresponding to the ancient condition of Apatkale 2. similar to the concept of Kutumbharthe 3. here the case was that of a mortgage but the lordships made it clear that the same principles would be applicable even in the case of sale or gift and that too by any member. Mussmat Babooee9 In this case the alienation made by a widow for the interest of her minor son was challenged. (1856)6 MIA313. the charge is one that a prudent owner would make in order to benefit the estate. In the case of a legal necessity. the precise nature of things to be included under the descriptions ‘benefit to the estate’ …. sale or gift ) of family property in a season of distress (for debt). . II 28-31. he is bound to set the application of money.594.honestly. However it differs in the powers of the father are much wider as Dayabhaga says that the father has absolute power to dispose off all kinds of ancestral property by sale.supra n.12 In this case the judges observed “ No indication is to be found in any of them(ancient texts) as to what is.7 p.supra n.Under Dayabhaga. The preservation however of the estate from extinction. 12 .e. 373. undoubtedly so that it can be suitably modified and expanded to include every act which might benefit the family. Daya. mortgage. for the purposes and benefit of the family (maintenance.Kutumbarthe(benefit of the family) and dharmarthe(religious purposes). in this connection. In the modern law the first exposition of the expression “for the benefit of the estate” was found in the case of Palaniappa v.11 1. education and marriages of members and other dependents) and particularly for religious purposes( Shraddhas and the like)” Therefore under the Mitakshara law the manager can validly make an alienation only in three circumstances i.10 The above given text gives the boundaries of karta’s power inside which he can alienate the joint property even without the consent of all the coparceners. . BENEFIT TO ESTATE The courts have not given a set definition of this concept. gift. the defence against hostile litigation affecting it. (1917)44 IA 147. the powers of the karta are similar to that of the Mitakshara. Apatkale(in times of distress). Ibid. 3 p. Literally translated it means “he has special powers of disposition (by mortgage. will or otherwise in the same way as he can dispose off his separate property. Deivasikamony. the protection of it or portions 10 11 . the real existence of an alleged sufficient and reasonably credited necessity is not a condition precedent to the validity of his charge and they do not think that under the circumstances. from injury or deterioration by inundations. Umrao Singh14. there and such like things would obviously be benefits” The Supreme Court later added its own observation as to what constitutes benefit. 37. however it has been recognized under the modern law that necessity may extend beyond that. Supra n. Instead in each case the court must be satisfied from the material before it. 2003. when a alienation was made to carry out renovations in the hotel which was a family business.P. Kamla Wati. it was held to be for benefit. . the courts have refrained from giving a set definition to the concept of legal necessity so as not to reduce it onto watertight compartment16. p. Legal Necessity Again as in the case of benefit of the estate. wars etc. when a land yielding no profit was sold and a land yielding profit was purchased the transaction was held to be for benefit. p. Apatkale essentially means situations of distress and emergency like floods.302.e. famines. 15 . fire. 2. 65. Indian Overseas Bank15. 801. that it was in fact conferred or was expected to confer benefit on family. AIR 1964 SC 1385. It can basically mean all acts done to fulfill the essential needs of the family members and only those acts which are deemed necessary. In Gallamudi v. The below given illustrations will give an idea as to the cases where the courts have held the alienation to be for benefit of the estate:In Hari Singh v. Thus it is now established that necessity should not be understood in the sense of what 13 14 .17 The shastric condition on which the concept of legal necessity i. Dr Paras Diwan. . AIR 1979 All. The concept of legal necessity is essentially one which may change and is thus in a state of flux.13 for the transaction to be regarded as for the benefit of the family it need not be of a defensive character. in the case of Balmukund v. AIR 1978 A.15th ed.MODERN HINDU LAW. 17 . 16 . is absolutely indispensable but what according to the notions of the joint hindu family would be regarded as proper and reasonable. medical care of the members of the family. upanayana. 16. p. payment of government dues etc. 16. Supra n. Right of Coparcener to Alienate his Share Sole Surviving Coparceners right to alienate-When joint family property passes into the hands of the sole surviving coparcener. and performance of necessary Sanskara19.V. 803.20 The major case in this regards is that of Gangi Reddi v. (1927)54 IA 136. it assumes the character nearly of his separate 18 19 .18 The following example would suitably illustrate the above stated principleFood shelter and clothing of the family members. 302. FAMILY LAW IN INDIA. Tammi Reddi21 In this the Judicial Committee held that a dedication of a portion of the family purpose of a religious charity may be validly by the karta without the consent of all the coparceners. for the payment of debts binding on the family. “and the like” may include many rituals and religious duties like sradha. Subbarao and Vijender Kumar. It also lays down the principle that the alienation should be made by the manager inter vivos and not de futuro by will. 2 p.77. marriage of the members of the family including daughters( special duty). supra n. . (rev. GCV Subba Rao.T. 20 . if the property allotted be small as compared to the total means of the family. 21 . .9th ed.2006. In the case of the marriage of the members of the family members it would come under the purview of both legal necessity as well as pious obligation as it is the most essential sanskara. p. defence of a family member involved in a serious criminal case. Supra n. Indispensable Duties The third ground upon which the authority of the managing member whether father or any other karta to make an alienation of family property rests is where the indispensable duties such as the obsequies of father and the like require it.). B. i. 28 . 27 . 15.22 In case a widow adopts a child after the death of her husband.property. 2 p. Supra n. the courts seized this principle and started executing personal money decrees against the joint family property. 821 . Thus barring the share of the widows he can alienate the other property as his separate property. 820. .e. Hanumant Rao 24 and Babronda v. 26 . 24 . Supra n. AIR 1950 Bom. (1877)4 IA 247.27 The law was settled in the case of Deen Dayal v. Coparceners Right to Alienate His Undivided Share – Under the shastric law no coparcener can dispose off his share without the express consent of the other coparceners.33p.E. 306. 25 .supra n. can the doctrine of relation back be applied in such cases The Mysore High Court in the case of Mahadevappa v. Chandabasappa 23held that such a child can actually challenge the alienation made by the sole surviving coparcener as he’ll have an interest in the joint family property This is in contrast with the stance taken by the Bombay High Court in the cases of Bhimji v.7 p. Anna 25 where it was held that a subsequently adopted son cannot divest a sole surviving coparcener of his right over the joint property and hence cannot challenge any alienation made by him. will such a child challenge the alienation. but if the son is born subsequent to the transaction then he cannot challenge the alienation. AIR 1965 Mys. Supra n. 16 p. AIR 1968 Bom. However this is not valid if another coparcener is present in the womb at the time of the alienation. with the only duty on him being that of maintenance of the female members (the widows) of the family. 8. 271.595. Jaidep28 where it was held that “purchaser of an undivided interest at an execution sale during the life of the debtor of his separate debt acquires his interest in such property with the power of ascertaining it and 22 23 . Since a single one of them has no power in any case to make a gift. Br (S.p. 384 verse 94) says “whether kinsmen are joint or separate they are equal as regards immovable property. sale or mortgage of it”26 Since the hindu sages laid great emphasis on payment of debts. 2. The rules regarding adopted son are corresponding. any person born afterwards is barred from doing the same. Ibid 33 . a coparcener can alienate his share even without the consent of the coparceners. Supra n. Art 144 gives the period for alienation made by karta as 12 years. coparcener or sole surviving coparceners overstep their power in making the alienation. Legal Recourse in case of Invalid Alienation If the father. alienation of undivided share is not allowed unless it is consented upon by every coparcener.29 As far as voluntary alienation is concerned there are several rules pertaining to different states-Under all the sub schools of Mitakshara. 277 .30 In the states of Maharashtra. it can be set aside by any other coparcener who has an interest in the property.16 p. such alienation cannot take place unless it is for legal necessity or benefit of the coparcener. AIR 1971 SC 776. Ambica Prasad33 where it was held that such alienations are merely voidable. Supra n . Only those coparceners who had been conceived at the time of the transaction are competent to challenge the alienation. from the time he comes to know of it till the time the suit is barred due to limitation Art 126 of the Indian Limitation Act 1908 sets the period of limitation for a suit by son challenging alienation made by the father as 12 years. Supra n . . 1956 a coparcener may dispose of his share in the family property by will. 315 32 . Under the codified law.3 p 397 31 . in case of mere declaration the period is 6 years. Madhya Pradesh and Madras. section 30 of the Hindu Succession Act. 1 p. Raghubanshi Narain Singh v. The limitation to this rule is that such a decree should be passed or has interest attached during his lifetime. karta.31 But in the states of Uttar Pradesh and West Bengal. 29 30 . The debate about whether alienation without necessity is void or voidable was put to rest by the Supreme Court in the case of R.32 Under Dayabhaga school of law coparcener is entitled to alienate his property inter vivo or by will.realizing it by partition”. nor can he get a conditional decree that alienation won’t be set aside until he is compensated. the actual presence or absence of such a necessity is irrelevant. Sivaramma 34 where it was held that :1. Supra n. other than that the standard of proof may be lowered if the courts feel that the hard evidence has been lost because of the time difference. Supra n .38 34 35 . Burden of Proof It has been laid down that in the case the alienation is made by the father for the payment of his debts. then he can neither enforce it against the coparcener who is entitled to make such alienation. 815. In case of suits filed by the coparceners. in this case the presumptions will also be accepted as evidence. and then the burden of proof is on the alienation to prove that he had taken sufficient care to determine that it was for the payment of debt. Madras High Court has given some vital rules in the case of Permanayakam v. Finally it was laid down in the case of Sunil Kumar v. 2. 36 . These principles were given in the case of Hunooman Persaud’s case.e.h. 10. immoral In the case the alienation was made by the karta it is again for the alienee to prove that he took sufficient care in finding out if the transaction was for necessity or no. AIR 1952 Mad 435. 2 p.If the suit is filed by the alienee. 37 . The sons can rebut this assumption only by proving that the debt was Avyavharik i. If alienation is only a device for distinguishing a gift. 38 . 16 p. 320. it may be set aside. .36 It is immaterial that there was earlier mismanagement of the estate if it can be proved that there was sufficient cause for the aliened to believe that there was an actual necessity which made it imperative that the alienation be made37 A lapse of time between the transaction and the filing of suit does not make any difference in the procedure. Ram Prakash35that a coparcener cannot ask for an injunction against alienation on the ground that it is not for legal necessity. . Supra n. the other coparceners don’t lose interest in the property or survivorship rights. AIR 1988 SC 576. If the alienation is made only for partial necessity. however once it was proved that he had taken due care. then the sum becomes the debt of the father which has to be paid by the sons. Sarmam Singh41the Privy Council held that in states where alienation can be totally set aside. The case of Sideshwar v . 565. 42 . Supra n . If the court is not satisfied as to the need to take such high interest then it may decrease the rate of interest. AIR 1954 SC 177. in such cases. 44 . supra n.e.16 p 330. supra n. this principle was laid down in the case of Padmanabh v. Supra n. Madhya Pradesh and Madras the ailenee can only file for specific property and not for a general partition. 819. the alienee would have no equity against his purchasing amount.39 Alienee’s Rights and Remedies In case the alienation is valid then there would be no problem as the alienee would automatically get all the rights of a mortgagee against the mortgager. Sundar 42the Calcutta High Court said that if the alienation made by the father was set aside. Bubheshwar 43 it was held that the alienee was not entitled to the mesne profit on the property from the day of the purchase till the day of the partition. hence they cannot set aside the alienation without refunding the purchasing price. In the states of Maharshtra.If the interest rate is unusually high then the burden of proof becomes twofold i. 817. 2 p. it has to be proved that there was a necessity to take a loan and then to prove that it was imperative to take the loan at such high rate. Madhya Pradesh and Madras where the alienation is set aside only to the extent of non alienating member’s share. 41 . the alienee maybe allotted a share different from what he purchased. 16 p. Even after this. However if the alienation is pronounced as invalid his situation is very unclearIn the states of Maharashtra. the alienee has no equity for the share of that member.40 In the case of Narayan Pd v. In the case Hasmat v. . Abraham44 which said that though it would be in all fairness kept in mind that the alienee be given the share 39 40 . 2 p. Supra n. 1917 PC 41. .327. however this decision has been criticized as this principle is violative of the antecedent rule. 43 . (1885)11 Cal 396. 3 p. . It must be noted that this is in accordance with the Mitakshara principle that “no member has a right without express agreement to claim a specific portion as his.he has purchased but he could be given other share if it causes injustice to the other coparceners. same applies to the alienee as he steps into the shoes of the coparceners. Chief among these are – firstly the total control which a father now has on over his separate movable and immovable property. The rules regarding conditions in which a valid alienation can be made are very practical and pragmatic for example the condition of Apatkale i. it provides the joint family members a chance to improve their standard of living by pooling their resources and utilizing them for their own benefit. This gives the power to him to use his share for purposes which may not qualify as necessity for the whole family but are very important for him. this is a safety net which saves people from utter ruin and gives them a chance to start afresh.e. a chance which is never given to the people in the supposedly highly civilized and progressive western nations. this is a departure from the ancient law which did not allow a father to dispose off his separate property according to his own wishes. Lastly we come to Dharmarthe i. The new changes made by the case law mostly by the Privy Council and the High Courts have been equally empowering and given the joint family members the power to use the property for their upliftment.CONCLUSION Alienation is one of the concepts which evolved during the basic construction of Hindu laws and it maintained its importance right throughout. those situations which may seem proper and reasonable to the court. This can be put to practical use for family benefit also in the shape of family business which is a common Indian occurrence. Secondly. in the time of distress gives actual utility of the joint family property because the share of all the members can be used to avert distress to any one of them. Hence religious purposes are as important as times of distress as they lead to deliverance. This has gone a long way in making the law of alienation much more suited to present conditions. this gives us an insight into the traditional Indian thinking where religion is a way of life. It also gives him a right to benefit from his share without severance from the joint family which occurs at the time of partition. Thirdly the ground of Apatkale has been satisfactorily extended to include along with situations of emergency and distress. the new powers given to alienate his share in the undivided family property for his own use with or without the consent of the other coparceners.e. alienations made for religious purposes. . Secondly coming to the condition of Kutumbarthe or ‘for the benefit of estate’. also he should be entitled to receive only that property which was alienated to him. Second. It should be noted that the courts in their haste to safeguard the interest of the non alienating coparceners. in my opinion his interest is more than a mere coparcener. the law according to which the purchaser loses all his interest in the joint property along with all the chance of getting back the purchasing amount is grossly unjust. in my opinion the alienee gets the worst bargain in the whole deal. Other than that some minor suggestions like the coparcener should be given the right to seek an injunction against alienations which can be proved to be invalid. Thirdly. starting from the alienation to the actual partition in case the alienation is proved to be valid. forget the interest of the innocent purchaser who has made a blna fide deal.However there still remain conditions where much is needed and where the judicial reforms have been conspicuous by their absence or have fallen short of their mark. Hence the first suggestions to improve the law of alienation are regarding :First. This should be so because the alienee being an outsider is not in a favourable position to ascertain it and such an obligation imposed on these transactions would make lenders unwilling to deal in joint property which would in turn adversely affect the rights of joint family members. Chief among these are the situation of the alienee in front of law. Hence sufficient recourses should be made for this. even in the case of a valid alienation the rights of the alienee are far from just and this should be accordingly changed so that the alienee is entitled to the mesne profit of the property from the day of the purchase instead of the day of the partition. the burden of proof of the alienee to prove that he took sufficient care to ascertain whether there was actual need should be lifted. instead in cases of invalid alienation it should be demanded of the alienor to prove that there was actual condition which demanded instant redress. . Lastly the position regarding the gifts of affection of immovable property should be made clear and uniform. Sarmam Singh Padmanabh v. Jaidep Gallamudi v. Kamla Wati Bhimji v. Anna Bachoo v. Chandabasappa Narayan Pd v. Sundar Hunooman Persaud v. Mangla Prasad Deen Dayal v. Deivasikamony Permanayakam v. Bubheshwar Subbarami v. Sivaramma R. Kishenkunkar Sideshwar v . Abraham Palaniappa v.TABLE OF CASES Cases Babronda v. Ram Prakash . Hanumant Rao Brij Narain v. Rammamma Sunil Kumar v. Mankore Bai Balmukund v. Mussmat Babooee Mahadevappa v. Tammi Reddi Hari Singh v. Umrao Hasmat v. Ambica Prasad Ramkoomar v. Indian Overseas Bank Gangi Reddi v. Raghubanshi Narain Singh v. HINDU LAW: A CRITICAL COMMENTARY. 2002. Butterworths Publications.C. R. FAMILY LAW IN INDIA. Subba Rao.J. Bharat Law House. T. 1st ed. Desai.M. 2004. Gogia & Company. S. 28th ed. G. Mayne’s TREATISE ON HINDU LAW & USAGE. 2nd ed.V. Hindu Law House. 2003. (rev. New Delhi. (rev. 2006. Pune. Acharya Shuklendra.V.A. HINDU UNDIVIDED FAMILY: TAXATION AND TAX PLANNING. Rao and Vijender Kumar. 2000 (rep. . S. 15th ed. Allahabad. Modern Law Publications. Divekar. MULLA PRINCIPLES OF HINDU LAW. 2003). New Delhi.Misra.BIBLIOGRAPHY G.). Hyderabad.). 9th ed.