Broadly a widow); and (c) The school of

Broadly speaking, whether a particular kind of property could be called stridhana would depend on the following three factors, viz. :

(a) The source from which the property was acquired;

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(b) The status of the woman at the time of acquisition (i.e., whether she was unmarried, married or a widow); and

(c) The school of Hindu law to which she belonged.

The ancient Smritis enumerate various types of stridhana. Thus, Manu gave a list of six kinds of property which fall under the term, viz.:

(i) Adhyagni — i.e., gifts made before the nuptial fire;

(ii) Adhyavahanika — i.e., gifts made at the bridal procession;

(iii) Pritidatta — i.e., gifts made by the father-in-law and mother- in-law out of affection. (This would also include padavandanika, i.e., gifts made at the time of making obeisance at the feet of elders just after marriage);

(iv) Gifts made by the father;

(v) Gifts made by the mother; and

(vi) Gifts made by the brother.

To this list, later Smriti-writers have added the following six more categories, viz. :

(i) Adhivedanika, i.e., gifts made on supersession;

(ii) Anwadheyaka, i.e., gifts by the husband’s relatives after marriage;

(iii) Sulka, i.e., gratuity or marriage fee;

(iv) Gifts from sons and relatives;

(v) Food and vesture; and

(vi) Ornaments given by the husband.

The different types of property enumerated by the Smriti-writers constitute what is known as technical stridhana, – as distinguished from stridhana in its literal or etymological sense.

It would also be relevant to quote Yajnavalkya, who defines stridhana in the following words:

“What was given (to a woman) by the father, the mother, the husband, or a brother, or received by her before the nuptial fire, or presented to her at her husband’s marriage, to another wife and the rest (adya) is denominated stridhana. So also, that which is given by kindred, as well as her marriage-fee (sulka) and anything bestowed after marriage.”

The Privy Council has held that property inherited by a woman, whether from a male or a female, is not her stridhana. This rule was well-settled in the Benares, Madras and Bengal schools. However, the Bombay school was of the view that such inherited property is not stridhana, only if it is inherited from a male by a widow, mother or other female entering into the gotra of the propositus by marriage.

Property obtained by a woman by adverse possession has also been held to be stridhana. (Sham Koerv. Dath Koer,— 29 I.A. 132). Likewise, unrealised rents and profits accruing from property given or bequeathed to a female during her widowhood has been held to be stridhana. (Mohinee Mohan Basu v. Rash Biharee Ghosh, 2 Cal. 97). So also, property purchased from stridhana is also stridhana. (Venkata v. Venkata, 2 Mad. 333 P.C.).