SASI K.G.
Manusmŗti III.32 defines a Gāndharva
marriage as, “32. The voluntary union of a maiden and her lover one must know
(to be) the Gāndharva rite, which springs from desire and has sexual
intercourse for its purpose[lxxxv].”
Yājñavalkyasmŗti
III.61 defines it as, “61. ……….. the Gāndharva by mutual consent[lxxxvi] ………..”
Nāradasmŗti XII.42 defines Gāndharva rite as, “42. The union of a
willing maiden with her lover is the fifth form, termed Gāndharva[lxxxvii]. …………”
Viṣṇusmŗti XXIV.23 defines Gāndharva
as, “23.
A union between two lovers, without the consent of mother and father, is called
a Gāndharva marriage[lxxxviii].”
Baudhāyana I.11.20.6 defines it as, “6. The union of a
lover with a loving damsel (is called) the rite of the Gandharvas (Gāndharva[lxxxix]).”
Āpastamba II. 5. 11. 20 defines Gāndharva
marriage as, “20. If a maiden and a lover unite themselves through love, that is called
the Gāndharva rite[xc].”
Gautama IV. 10 defines it as, “10. The spontaneous
union with a willing (maiden is called) a Gāndharva wedding[xci].”
Āśvalāyana Gŗhya Sūtras
I.6.5 defines the Gāndharva rite as, “5. He may marry her, after a mutual agreement has
been made (between the lover and the damsel): this (is the wedding called) Gāndharva[xcii].”
According to Vasiṣṭha
I.33, Gāndharva marriage is, “33. If a lover takes a loving female of equal caste,
that (is called) the Gāndharva rite[xciii].”
In Chapter
V of Part III of the Kāmasūtra of Vātsyāyana it is also stated, “As the
fruit of all good marriages is love, the Gāndharva form of marriage is
respected, even though it is formed under unfavourable circumstances, because
it fulfills the object sought for. Another cause of the respect accorded to the
Gāndharva form of marriage is, that it brings forth happiness, causes
less trouble in its performance than any other forms of marriage, and is above
all the result of previous love[xciv].”
Nāradasmŗti XII.72 states, “72. When, however, he
has connection with a willing maiden, it is no offence, but he shall bestow ornaments
on her, honour her (with other presents), and (lawfully) espouse her[xcv].”
As most of the
marriages of the ancient Hindus were solemnized before the puberty of girls, it
was natural that Gāndharva rite did not get prominence. However it was
not condemned. But whenever a maiden passed the three years after the age of
puberty as mentioned in Vasiṣṭha XVII.67-68 or the first three
monthly periods as prescribed by Vișṇusmŗti XXIV. 40-41 she was
allowed to select her own husband. Thus it can be rightly said that Gāndharva
is prescribed to grown up girls.
Manusmŗti III.33 defines a Rākșasa
marriage as, “33. The forcible abduction of a maiden from her home, while she
cries out and weeps, after (her kinsmen) have been slain or wounded and (their
houses) broken open, is called the Rākșasa rite[xcvi].”
Yājñavalkyasmŗti
III.61 defines it as, “61. ……….. the Raksasa by forcible taking by waging war[xcvii] ……….”
Nāradasmŗti XII.43 defines Rākșasa
rite as, “43. The Rākșasa form is declared to consist of the forcible
abduction of a maiden[xcviii]. ……...”
Viṣṇusmŗti XXIV.25 defines Rākșasa
as, “25.
If he seizes her forcibly, it is called a Rākșasa marriage[xcix].”
Baudhāyana I.11.20.8 defines it as, “8. (If the maiden is
wedded) after being forcibly abducted, (that is) the rite of the Rākșasas
(Rākșasa[c]).”
Āpastamba II. 5. 12.2 defines Rākșasa
marriage as, “2. If the (bridegroom and his friends) take away (the bride), after having
overcome (by force) her father (or relations), that is called the Rākșasa
rite[ci].”
Gautama IV. 12 defines it as, “12. (If the bride) is
taken by force, (that is) a Rākșasa wedding[cii].”
Āśvalāyana Gŗhya Sūtras
I.6.8 [ciii]defines
the Rākșasa rite as, “8. He may carry her off, killing (her relatives) and cleaving
(their) heads, while she weeps and they weep: this (is the wedding called) Rākșasa.”
According to Vasiṣṭha
I.34, Rākșasa marriage is, “34. If they forcibly abduct (a damsel),
destroying (her relatives) by strength (of arms), that (is called) the Kshatra-rite[civ].” Here the words Rākșasa
and Kshatra make the same sense.
In Chapter
V of Part III of the Kāmasūtra of Vātsyāyana it is also stated, “When
the girl goes to a garden, or to some village in the neighbourhood, the man
should, with his friends, fall on her guards, and having killed them, or
frightened them away, forcibly carry her off, and proceed (for marriage) as
before[cv].”
Rākșasa rite is in the
nature of forcible abduction of the girl. The words forcibly, by force,
killing, weeps, destroying etc. suggest that the love of the girl is immaterial
in this case. After abduction Baudhāyana also suggests the
necessity of a formal marriage.
Manusmŗti III.34 defines a Paiśāca
marriage as, “34. When (a man) by stealth seduces a girl who is sleeping,
intoxicated, or disordered in intellect, that is the eighth, the most base and
sinful rite of the Piśācas[cvi].”
Yājñavalkyasmŗti
III.61 defines it as, “61. ……………..and Paiśāca by deceiving the girl[cvii].”
Nāradasmŗti XII.43 defines Paiśāca
rite as, “43. ………… Sexual intercourse with a woman during her sleep or while she is unconscious
(of the approach of a man) constitutes the eighth form, the basest of all[cviii].”
Viṣṇusmŗti XXIV.26 defines Paiśāca
as, “26.
If he embraces her in her sleep, or while she is unconscious, it is called a Paiśāca marriage[cix].”
Baudhāyana I.11.20.9 defines it as, “9. If one has
intercourse with (a maiden) who is sleeping, intoxicated, or out of her senses
(with fear or passion and weds her afterwards, that is) the rite of the Piśacas (Paiśāca[cx]).”
Gautama IV. 13 defines it as, “13. If (a man) embraces
a female deprived of consciousness, (that is) a Paiśāca wedding[cxi].”
Āśvalāyana Gŗhya Sūtras
I.6.7 defines the Paiśāca rite as, “7. He may carry her off while (her relatives)
sleep or pay no attention: this (is the wedding called) Paiśāca[cxii].”
In Chapter
V of Part III of the Kāmasūtra of Vātsyāyana it is also stated, “The
man should on the occasion of festivals get the daughter of the nurse to give
the girl some intoxicating substance, and then cause her to be brought to some
secure place under the pretence of some business, and there having enjoyed her
before she recovers from her intoxication, should bring fire from the house of
a Brāhman, and proceed (for marriage) as before.
The man
should, with the connivance of the daughter of the nurse, carry off the girl
from her house while she is asleep, and then, having enjoyed her before she
recovers from her sleep, should bring fire from the house of a Brāhman,
and proceed (for marriage) as before.[cxiii]”
Brhaspatismŗti
XXIII.3-4 and 10-11 treats the Paiśāca intercourse as an offence
under adultery and severe punishment is prescribed for the culprit as under.
“3. When a man has
intercourse with a woman in secret against her will, when she is asleep, or
disordered in her intellect, or does not notice his approach, it is (termed)
forcible enjoyment of a woman.
4. When he conducts
her into his house under false pretences, and after giving her intoxicating drugs,
has intercourse with her, it is considered fraudulent enjoyment of a woman.
10. (The king) shall
confiscate the whole wealth of him who violates an unwilling woman, and having caused
his penis and scrotum to be cut off, shall cause him to be paraded on an ass.
11. When a man enjoys
a woman by fraud, his punishment shall be confiscation of his entire wealth, and
he shall afterwards be branded with the mark of a female part and banished from
the town[cxiv].”
Other authors also
prescribe punishments for the culprit if offender does not marry the victim.
The main ingredients
of Paiśāca marriage is the inability of the girl to understand what is
happening and the fraudulent sexual enjoyment of the woman. Some authors
prescribe that this marriage may be resorted to if a man does not get a girl
from anywhere. Paiśāca rite is the result of the fraudulent offence. If
the offender does not marry the victim, then he shall be put to severe
punishment. Paiśāca marriage is termed as the most sinful, base and mean
of all kinds of marriages.
Manusmŗti IX. 96 declares, “96. To be
mothers were women created, and to be fathers men; religious rites, therefore,
are ordained in the Veda to be performed (by the husband) together with the
wife[cxv].”
Manusmŗti IX. 101-103 adds, “101. ‘Let
mutual fidelity continue until death,’ this may be considered as the summary of
the highest law for husband and wife.
102. Let man and
woman, united in marriage, constantly exert themselves, that (they may not be)
disunited (and) may not violate their mutual fidelity.
103. Thus has been declared
to you the law for a husband and his wife, which is intimately connected with
conjugal happiness, and the manner of raising offspring in times of calamity[cxvi]; ………”
The other authors
have more or less similar views on the purpose of marriage. They maintained
that the primary duty of the marriage sacrament was to keep the sacred law
(dharma) and that sensual happiness was secondary.
Manusmŗti III.39-42 states, “39. From
the four marriages, (enumerated) successively, which begin with the Brāhma
rite spring sons, radiant with knowledge of the Veda and honoured by the Śishtas (good men.)
40. Endowed with the
qualities of beauty and goodness, possessing wealth and fame, obtaining as many
enjoyments as they desire and being most righteous, they will live a hundred
years.
41. But from the
remaining (four) blamable marriages spring sons who are cruel and speakers of
untruth, who hate the Veda and the sacred law.
42. In the blameless
marriages blameless children are born to men, in blamable (marriages) blamable
(offspring); one should therefore avoid the blamable (forms of marriage[cxvii].)”
Nāradasmŗti XII.44 opines, “44. Of these, the
(first) four, beginning with the Brāhma form, are declared to be lawful;
the Gāndharva form is common (to all castes); the three forms, which
come after it, are unlawful[cxviii].”
Viṣṇusmŗti XXIV.27-28 states, “27. Among those
(eight forms of marriage), the four first forms are legitimate (for a Brāhmaṇa)
;
28. And so is the Gāndharva
form for a Kșatriya[cxix].”
According to Gautama
IV. 14-15, “14. The first four (rites) are lawful;
15. Some say, (the
first) six[cxx].”
Thus Rākșasa
and Paiśāca marriages are unlawful to Gautama.
Āpastamba II.5.12.3-4 maintains, “3. The first three
amongst these (marriage-rites are considered) praiseworthy; each preceding one better
than the one following.
4. The quality of the
offspring is according to the quality of the marriage-rite[cxxi].”
Baudhāyana
I.11.20.10-16 gives more details, “10. Among these (eight rites) the four first
(named) are (lawful) for a Brāhmaṇa. Among these also each earlier named
is preferable.
11. Among the (four)
later (named rites) each succeeding one is more sinful (than the preceding ones).
12. Among these the sixth
and the seventh agree with the law of the Kșatriyas. For power is their attribute.
13. The fifth and the
eighth (are lawful) for Vaiśyas and Śudras.
14. For Vaiśyas and Śudras
are not particular about their wives,
15. Because they are
allowed (to subsist by such low occupations as) husbandry and service.
16. Some recommend
the Gāndharva rite for all (castes), because it is based on (mutual)
affection[cxxii].”
However the stand of Arthaśāstra
of Kauțilya that all is well if everybody is happy fits in here. But if a complaint
arises, and an offence is recognized, the unlawful marriages become offences of
great punishments.
Many ancient Hindu Laws were struck down by
Competent Courts for the single reason of becoming obsolete as in the case of putrikāputra succession in Shyam Sunder Prasad Singh & Ors. v. State of Bihar
& Ors. (1981 AIR 178, 1981 SCR (1) 1). Thus by declaring all types of
marriage except the Brāhma, Āsura and Gāndharva as
obsolete as in Maharaja of Kolhapur vs S.
Sundaram Ayyar And Ors (AIR 1925 Mad 497) read with Kamani Devi v. Kameshwar Singh (ILR 25 Pat 58 = AIR
1946 Pat 316).
For the purpose of
Succession therefore only the cases of Brāhma, Āsura and Gāndharva
types of marriages need be considered. Manusmŗti IX. 194-197 runs
as follows,
“194. What (was
given) before the (nuptial) fire, what (was given) on the bridal procession,
what was given on token of love, and what was received from her brother,
mother, or father, that is called the six-fold property of a woman.
195. (Such property),
as well as a gift subsequent and what was given (to her) by her affectionate
husband, shall go to her offspring, (even) if she dies in the life time of his
husband.
196. It is ordained
that the property (of a woman married) according to the Brāhma, the Daiva,
the Ārșa, the Gandarva or the Prājāpatya rite (shall belong) to
her husband alone, if she dies without issue.
197. But it is
prescribed that the property which may have been given to a (wife) on an Āsura
marriage or (one of the) other (blamable marriages, shall go) to her mother and
to her father, if she dies without issue[cxxiii]. ”
Jīmūtavāhana IV.2. 27-28 comments on these
and states,
“27……………………………..The
phrase "what was given to a woman" in the second verse also applies
in the first. As a result, the combination "what was given at any kind of
wedding" makes it clear that Manu 9.196 pertains to property given at
weddings only, not to any kind of property whatever.
28. Yama's verse:
Whatever
property is given at an Āsura or other lower forms of wedding, pertains to property
that is given while the successive rites of the wedding ceremony are in
progress. It is clear, therefore, that this applies only to property received at
the wedding[cxxiv]”
However since the
enactment of the Hindu succession Act, 1956 the ancient Hindu Laws were
repealed to a major extent as provided in Section 4 of the Act which runs,
“4.(1) Over-riding
effect of Act. Save as otherwise expressly provided in this Act,-
(a) any text,
rule or interpretation of Hindu law or any custom or usage as part of that law
in force immediately before the commencement of this Act shall cease to have effect
with respect to any matter for which provision is made in this Act ;
(b) any other law
in force immediately before the commencement of this Act shall cease to apply
to Hindus in so far as it is inconsistent with any of the provisions contained
in this Act.”
Thus the succession
as per ancient Hindu Law based on the type of marriage seems limited to the
property of a woman died in or before 1956.
In Maine’s
Hindu Law and Usage it is stated that, “Marriage, as Methatithi,
the commentator of Manu, says, ‘has been classified under eight
heads on the basis of different methods used for taking wives; and it does not
mean that there are eight kinds of marriage.’ These eight methods of obtaining
a wife really resolve themselves into three forms of marriage, namely, the gift
of the bride, the sale of the bride and the agreement between the man and the
woman[cxxv].” In
Para 99, page 117 of the book it is stated, “99. All obsolete except three.- Of
these various forms of marriage, all but three, the Brāhma, Gāndharva
and Āsura, are now obsolete[cxxvi].”
In Authikesavalu Chetty v. Ramanujan Chetty (1909) 32 Mad
512
Madras high Court has held that “The essence of the Brāhma form of
Marriage is that it is a gift of the daughter in marriage; accordingly, it is
said that the distinctive mark of the Āsura form is the payment of money
for the bride; as the absence of that payment (a marriage) is of the approved
form.” The Madras Sudder Court held in 1859 that in the case of Śudras, the
mere fact that the bride is given without the bestowal of any gift by the
bridegroom constitutes the marriage one of the Brāhma form. Thus the Brāhma
form of Marriage was accepted by Indian Courts as applicable not only to
Brahmins but also to all citizens of India.
In Hira v. Hansji of Bombay High Court ((1913) 37 Bom 295,
301 it
has been upheld that the Āsura form was the only surviving unapproved
form of a valid marriage, every other marriage must be regarded as not
unapproved.
Maine Page 118 Para
100 continues that “A similar presumption must be applied in connection with
the remarriage of widows (see Moosa, Haji
Joonus v. Haji Abdul Rahim (1906) 30 Bom 197) and has been applied to the customary form of
marriage called the Karao marriage (see Kishen
Dei v. Shen Palton (1926) 48 All 126) or a pat marriage (see Mahadeo v.
Chandrabhagabai ILR (1946) Nag 378)[cxxvii].”
In 1817 Bengal
Saddar Court ruled that Gāndharva marriages in India were legal. Allahabad
High Court in Bhaoni v. Maharaja Singh,
(1881) ILR 3 All 738 condemned the Gāndharva form of marriage in strong terms
by describing it as nothing more or less than concubinage and that it had
become obsolete as a form of marriage. In 1925 the Madras High Court held that
so far as the said eight forms of marriages referred to in the Shastras are
concerned it is now accepted law that all except the Brāhma and Āsura
forms are obsolete (Maharaja of Kolhapur
vs S. Sundaram Ayyar And Ors (AIR 1925 Mad 497)). In 1930, Judge Abdur Rahim of Madras
High Court held that the marriage in Gāndharva form was not valid in
India on the ground that the Gāndharva form of marriage was obsolete. A
similar judgment was issued in Ram Pearey
v. Mst. Kailasha (AIR 1930 Oudh 426) also.
The Patna
High Court in Kāmani Devi v. Kameshwar
Singh, ILR 25 Pat 58 = (AIR 1946 Pat 316) held that the relationship of husband and
wife, created by such a marriage is binding against each other and the husband
cannot escape his liability of maintaining his wife married in Gāndharva
form. The High Court went further and held that the celebration of Gāndharva
form of marriage must be attended with nuptial rites and ceremonies including
Homa (invocation before the sacred fire) and Saptapadi (the taking of seven
steps by the bride-groom and the bride together) for its validity, This was
approved by the Supreme Court in the case of Bhaurao v. State of
Maharashtra (1965 AIR 1564,
1965 SCR (2) 837) as “
The two ceremonies essential to
the validity of a Hindu marriage, i.e. invocation before the sacred
fire and saptapadi, are also a requisite part of a 'Gāndharva' marriage
unless it is shown that some modification of
these ceremonies has been
introduced by custom in any particular community
or caste.”
In Ram Chandra Bhattacharjee v. Manju Bhattacharjee (AIR
1975 Cal 118), Judge Mukherji noted, "Gāndharva form of marriage
should not be regarded as concubinage or quasi-marital union, more so in the
context of the modern Society and in the background of the forward thinking of
the present law givers. The possibility of legal validity of this form of
marriage in the whole of India in near future even without being backed by custom
is too notorious to be ignored. In a sense, Gāndharva form of marriage
is trying to come back very fast (in India), pushing parental domination to the
background."
The Supreme Court
further dictated in that case a seven point guideline to be followed to make a Gāndharva
marriage valid as given below.
“In so far
as the law is administered in India unto the present day, even after the
passing of the Special Marriage Act and Hindu Marriage Act, the
following principles about the Gāndharva form of marriage are to be
followed:
(i)
Marriages in Gāndharva form though have fallen into disuse in West
Bengal are not altogether obsolete in all the States of India, and particularly
between the parties governed by the Mithila School of Hindu Law.
(ii) A
marriage in Gāndharva form may be completed by the performance of
ceremonies, other than Homa and Saptapadi where it is allowed by the custom of
the caste to which the parties belong.
(iii)
Custom, however, to be valid and to have the force of law, it must be
continuous for a long time, uniform, certain, moral, reasonable and not opposed
to public policy and not in derogation of Hindu Law or Statute. There must be
evidence to sustain the custom.
(iv) Minors
cannot perform this type of marriage.
(v) There is
no necessity of formal transfer of the dominion of the daughter by the parents
to the husband.
(vi) A bare agreement coupled with declaration and even living together as husband and wife after the
exchange of garlands and rings are insufficient to establish a valid marriage under the Gāndharva form.
The doctrine of 'factum valet' cannot be invoked in such circumstances either.
(vii) Gāndharva form of marriage should not be regarded as concubinage or quasi-marital union, more so
in the context of the modern Society and in the background of the forward thinking of the present law givers.
The possibility of legal validity of this form of marriage in the whole of India in near future even without being
backed by custom is too notorious to be ignored. In a sense, Gāndharva form of marriage is trying to come
back very fast pushing parental domination to the background.”
In Vijiarangam v. Lakshmanan (1871) 8 BHCOCJ. 224, 254,
255 West J.
considered that the very name of Āsura indicated it as one derived from
the aboriginal inhabitants of this country or those occupying it before the
Aryan invasion and that it was the reason why it was loathed by the sages of
the strict Bhahmanical school.
In Authikesavalu Chetty v.
Ramanujan Chetty (1909) 32 Mad 512 Madras high
Court observed that “…among the Tamil population the Āsura form of
marriage is universal, and that the Brāhma form, which is known as
Kanyakādānam, or gift of
a virgin, is not thought reputable, and that the son in law so married is
considered to become adopted into the family of his father in law, and loses
his right of succession in his natural family.” The Court further found that
the Āsura is still practiced and in South India, among the Śudras it is
a very common, if not the prevailing form.
The Census Report of 1891.1.117, 118 states that “In
Assam, as a rule, women are looked upon as a species of propertyto be bought
with a price, or by service in the father’s house. The Gharos and Khasis alone
do not purchase their wives.”
In Keshow Rao v. Naro 3 Bor. 198
(215, 221) the Śastries stated that, although Āsura marriages were forbidden, it
had nevertheless been the custom for Brahmins and others to celebrate such
marriages, and that no one had ever been expelled from caste for such an act.
In Hira v. Hansji of Bombay High Court ((1913) 37 Bom 295 it was held that
money paid to the parents of the bride to be paid to her third husband to
procure her divorce was not bride price and the marriage was not in the Āsura
but in the Brāhma form.
In A.L.V.R.S.T.
Veerappa Chettiar v. S. Michael etc. 1963 AIR 933, 1963(2) Suppl. SCR 244
the Supreme Court has observed that the fact that the bridegroom's party bears
the expenditure may be due to varied circumstances. Prestige, vanity, social
custom, the poverty or the disinclination of the bride's father or some of them
may be the reasons for the incurring of expenditure by bridegroom's father on
the marriage but the money so spent is not the price or consideration for the
bride.
But in Muthu v. Chidambara (1983) 3 MLJ 261 it is held that where the bridegroom or his party gives a sum
of money to the father of the girl towards the expenses of the marriage, it is
equivalent to bride price and that the marriage should be regarded as an Āsura
marriage.
There are other
numerous cases identifying the existence of Āsura marriages in India.
In A.L.V.R.S.T.
Veerappa Chettiar v. S. Michael etc. 1963 AIR
933, 1963(2) Suppl. SCR 244 the Supreme Court has held that presumption
is that every Hindu marriage is in Brāhma
form and that the objector must prove the contrary.
1. There is an
inherent conflict in the Indian legal system in the application of Hindu Laws.
There has always been a tendency to curtail the authority of ancient Hindu Laws
first by discarding some authors and then by limiting the divergent Hindu Law
to a few authors. The ancient Hindu Laws gradually were substituted by secular
Hindu Legislation. Even while doing so certain Hindus such as the Tribal people
were kept outside its purview and some other people who were not the followers
of Hindu Religion were forced to follow the ancient Hindu Laws in the guise of
customs.
2. Śrutis and Smŗtis are the main sources of ancient Hindu Law.
3. Marriages of girls
were done before attaining puberty and the dominion of the marriage was under the
control of their fathers. However the girls would get the right to choose their
husbands, if their parents did not give them in marriage within three years
after attaining their puberty.
4. Remarriage was
allowed. But widow marriages were not generally supported.
5. The hymns sung at
the time of marriages were prescribed by the Śrutis.
6-14. Generally eight
types of marriages were recognized, namely Brāhma, Daiva, Ārșa, Prājāpatya,
Āsura, Gāndharva, Rākșasa, and Paiśāca.
15. To maintain the
family line, to do the dharma jointly and to show mutual loyalty is the essence
of every marriage.
16. The first four of
the eight types are lawful; some say the first six. According to Arthaśāstra if
nobody has any complaint every type is good.
17. As the Hindu Marriage
Act, Hindu Succession Act and similar other laws have been enacted there is
very little scope for the application of ancient Hindu Laws.
18. Law presumes that
all types of marriages except Brāhma, Gāndharva and Āsura
rites are obsolete. If not otherwise proved, the law presumes that all
marriages belong to the Brāhma rite. The onus to prove otherwise is with
the objector. Even in the case of Gāndharva and Āsura marriages
prescribed function with fire and saptapadi has to be fulfilled to get the marriage
declared as good.
NOTES
[xc]
SBE, Vol 2, Page 127
[xci]
SBE, Vol 2, Page 195
[xciv]
The
Kamasutra Aphorisms on Love by Vatsyayana, Translated by Sir Richard Burton,
Electronic version, Page 71-72
[xcv]
SBE, Vol 33, Page 179
[c]
SBE, Vol 14, Page 206
[ci]
SBE, Vol 2, Page 127
[cii]
SBE, Vol 2, Page 195
[civ]
SBE, Vol 14, Page 6
[cv] The
Kamasutra Aphorisms on Love by Vatsyayana, Translated by Sir Richard Burton,
Electronic version, Page 71-72
[cvi]
SBE, Vol 25, Page 81
[cix]
SBE, Vol 7, Page 108
[cx]
SBE, Vol 14, Page 206
[cxi]
SBE, Vol 2, Page 195
[cxiii]
The
Kamasutra Aphorisms on Love by Vatsyayana, Translated by Sir Richard Burton,
Electronic version, Page 71-72
[cxiv]
SBE, Vol 33, Page 365-366
[cxv]
SBE, Vol 25, Page 344
[cxx]
SBE, Vol 2, Page 195
[cxxiv]
Jimutavahana's
Dayabhaga, The Hindu Law of Inheritance in Bengal, Edited and Translated
by Ludo Rocher, 2002, OXFORD, Page 118
[cxxv]
Maine’s Hindu Law & Usage 15th
Edition, Page 114-115 Para 95
[cxxvi]
Maine’s Hindu Law & Usage 15
th Edition,
Page 117, Para 99
[cxxvii]
Maine’s Hindu Law & Usage 15
th Edition,
Page 118, Para 100
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