Tuesday, February 23, 2016

DIFFERENT TYPES OF MARRIAGES UNDER THE ANCIENT HINDU LAW - PART II



SASI K.G.

12. What is a Gāndharva Marriage?


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.

13. What is a Rākșasa Marriage?

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.

14. What is a Paiśāca 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.

15. What is the Purpose of Marriage according to Ancient Hindu Law?

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.

16. What are the Lawful and Unlawful Marriages according to Ancient Hindu Law?

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.

17. What are the Effects of Different Types of Marriage in the Succession Laws?

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.

18. What are the Presumptions of Present Indian Legal System on Different Types of Marriage?

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].”

Gāndharva

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.”

Āsura

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.

Brāhma

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.

19. Recapitulation

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


[lxxxv] SBE, Vol 25, Page 81
[lxxxvi] SBH, Vol 21, Page 126
[lxxxvii] SBE, Vol 33, Page 174
[lxxxviii] SBE, Vol 7, Page 108
[lxxxix] SBE, Vol 14, Page 206
[xc] SBE, Vol 2, Page 127
[xci] SBE, Vol 2, Page 195
[xcii] SBE, Vol 29, Page 166
[xciii] SBE, Vol 14, Page 6
[xciv] The Kamasutra Aphorisms on Love by Vatsyayana, Translated by Sir Richard Burton, Electronic version, Page 71-72
[xcv] SBE, Vol 33, Page 179
[xcvi] SBE, Vol 25, Page 81
[xcvii] SBH, Vol 21, Page 126
[xcviii] SBE, Vol 33, Page 174
[xcix] SBE, Vol 7, Page 108
[c] SBE, Vol 14, Page 206
[ci] SBE, Vol 2, Page 127
[cii] SBE, Vol 2, Page 195
[ciii] SBE, Vol 29, Page 167
[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
[cvii] SBH, Vol 21, Page 126
[cviii] SBE, Vol 33, Page 174
[cix] SBE, Vol 7, Page 108
[cx] SBE, Vol 14, Page 206
[cxi] SBE, Vol 2, Page 195
[cxii] SBE, Vol 29, Page 167
[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
[cxvi] SBE, Vol 25, Page 345
[cxvii] SBE, Vol 25, Page 82-83
[cxviii] SBE, Vol 33, Page 174
[cxix] SBE, Vol 7, Page 108
[cxx] SBE, Vol 2, Page 195
[cxxi] SBE, Vol 2, Page 127
[cxxii] SBE, Vol 14, Page 206-207
[cxxiii] SBE, Vol 25, Page 370-371
[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 15th Edition, Page 117, Para 99
[cxxvii] Maine’s Hindu Law & Usage 15th Edition, Page 118, Para 100

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4. The Sacred books of the East Volume 25 – Manusmiti with several partial commentaries, Edited by Max Muller, 1886, Oxford
5. The Sacred books of the East Volume 29 – Gŗhya Sutras Part 1 – Sankhyayana, Asvalayana, Parasara, Khadia, Edited by Max Muller, 1886, Oxford
6. The Sacred books of the East Volume 30 – Grihya Sutras Part 2 – Gobila, Hiranyakeshin,Apastamba, Yagna Paribhashasutras, Edited by Max Muller, 1892, Oxford
7. The Sacred books of the East Volume 33 – Minor Law Books – Narada and Bŗhaspati, Edited by Max Muller, 1889, Oxford
8. The Sacred books of the East Volume 42 – Atharva Veda  – Hymns, some rituals and commentaries, Edited by Max Muller, 1897, Oxford
9. The Sacred books of the East Volume 46 – Rg Veda – Mandalas 1-5 - Agni, Edited by Max Muller, 1897, Oxford
10. The Sacred books of the Hindus Volume 21 – Yājñavalkya Smriti, Mitaksara and Malambhatta – Book I – Achara Adhyaya, Translated by Rai Bahadur Srisa Chandra Vidyarnava, June 1918, Published by Sudhindra Nath Vasu
11. Hindu Law By J.R. Gharpure, 1905, Published by Maruti Babaji
12. Hindu Law and Judicature from the Dharmaśāstra of Yājñavalkya, By Edward Roer and W.A. Montriou, 1859, Published by R.C. Lepage & Co., British Library, Calcutta.
13. The Institutes of Parasara Translated By Krishnakamal Bhattacharya, 1887, Published by Asiatic Society of Bengal (New series No. 567)
14. The Hindu Law being a treatise on the law administrated exclusively to Hindus by the British Courts of India, By Herbert Cowell, 1871, Published by Thacker Spink & Co., Calcutta.
15. The Memoirs of Jahangueir Translated by Rogers, 1909, Published by Royal Asiatic Society
16. The Vedas, Issue 1, Draft 2, 24.11.2002, Compiled by the Dharmic Scriptures Team
17. The MahaBharata of Krishna-Dwaipayana Vyasa Translated into English Prose Adi Parva Translated by Kisari Mohan Ganguli, 2005 Electronic version of Project Gutenberg.
18. Kautilya’s Arthashastra, Translated and Published by R. Shamasastri, Electronic version.
19. Universal’s Hindu Laws, 2003 Published by Universal Law Publishing Co. Pvt. Ltd.
20. Maine’s Hindu Law & Usage 15th Edition, Revised by Justice Ranganath Misra, 2003  Published by Bharat Law House, New Delhi
21. Constitution of India modified upto 01.12.2007, Published by the Ministry of Law and Justice, Government of India.
22. Jimutavahana's Dayabhaga, The Hindu Law of Inheritance in Bengal, Edited and Translated by Ludo Rocher, 2002, OXFORD
23. The Mithakshara with Visvarupa and Commentaries of Subodhini Balambhatti, Edited by S.S.Setler, 1912, Brahmavadin Press, Georgetown, Madras
24. The Kamasutra Aphorisms on Love by Vatsyayana Translated by Sir Richard Burton, electronic version
25. The Hindu Marriage Act, 1955
26. The Hindu Succession Act, 1956
27. Hindu Marriages (Validation of Proceedings) Act, 1960
28. Wikipedia
29. http:// Indiankanoon.org
30. And many other internet resources

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