CONTENTS

I. INTRODUCTION......................................................................................0

II. CONCEPT OF JOINT FAMILY...............................................................1

III. HINDU WOMEN'S RIGHT TO PROPERTY ACT, 1937........................3

IV. CONCEPT OF COPARCENARY.............................................................5

V. DISCTINCTION BETWEEN JOINT HINDU FAMILY AND HINDU

COPARCENARY......................................................................................7

VI. ROLE OF SURVIVORSHIP.....................................................................8

VII. RIGHTS OF WOMEN...............................................................................9

VIII. WOMEN PROPERTY RIGHTS AND THE STATUTORY LAWS......10

IX. CONCLUSION........................................................................................15

X. BIBLIOGRAPHY....................................................................................16

0
 INTRODUCTION

The concept of property and the rights relating to property have been embedded in the social
life and the social structure of human civilization for a very long time . And every religion
across the world construes property and the rights related to property in their own sense, there
exists cultural, constructional as well as ideological differences across the world.

A shift in the dominance of religion on property was seen post the industrial revolution which
led to increase in the economic as well as political rights philosophy . We then witness the
emergence of human rights after the United Nations Declaration of Human Rights, which lay
down property as essential human right and prohibits any sort of deprivation in that regard .
Gender equality in property rights is a critical human rights issue in present socio-economic
realities and this concept differs from one society to another . Equal distribution of property
contributes towards the real empowerment of woman and considered as the key factor in
socio-economic development process.1

The Code of Gentoo Laws is the first example of codified Hindu personal laws. In 1772, this
was formulated by a group of 11 pandits, under guidance of Warren Hastings, to compile a
code in Hindu Laws. This helped create an illusion that formulation of laws was still in the
hands of Brahmins. The next round of modifications was carried out 20 years later where the
final Digest of Hindu Law was compiled by H.T. Colebrooks.

The status of property rights of woman under Hindu religio-legal system has always been
considered as a debatable issue both from religious and secular approach in jurisprudential
discourse.

The constitution of India provides for justice – social, economic and political, when read
along with Article 14, it provides for right to equality before the law . In practice this

guarantee has been read to infer ‘substantial’ equality as opposed to ‘formal’ equality . The
latter dictates that only equals must be treated as equals and that unequal may not be treated
as equals. This broad paradigm itself permits the creation of affirmative action by way of

1
Mollah, Md.Al. Hindu Women’s Right to Property at the Crossroads: the Tension between Human Rights and
Cultural Relativism. Journal of Society and Change. VIII. 84. 2015.

1
special laws creating rights and positive discrimination by way of reservations in favour of
weaker classes of society.

Gender inequality presents itself in various forms across the legal faction, but the most
relevant and tiresome is one of the property rights of women. The parliament enacted the
Hindu Succession Act, 1956.

CONCEPT OF JOINT FAMILY

The Smrities and Commentaries, with their roots in a feudal society of agrarian landholdings,
prescribed a patriarchal family structure within which women's right to property was
constrained. Under Hindu Law, the law of property has a close relationship with the

composition of family.

The institution of a Hindu Joint Family is peculiar to the Hindu jurisprudence and has its
origin in ancient orthodox texts and writings of Smritikars etc . Its origin can be traced to the
ancient patriarchal system where the patriarch or the head of the family was the unquestioned
ruler, laying down norms for the members of his family to follow, obeyed by everyone in his
family and having an unparalleled control over their lives and properties.

The ancient system generally treated the property acquired by the member of the family as
family property or the joint property of the family with family members having one or the
other right over it. With gradual transformation of the society and recognition of the members
of the family as independent in their own right, concept of separate property and rules for its
inheritance were developed. This dual property system, though considerably diluted, has
survived the lashes of time, the judicial and legislative onslaught and the Hindu society still
recognizes the joint family and joint family property as unique entities having no similar
concept alive elsewhere in the world

A joint Hindu family consists of all male members lineally descended from a common male
ancestor and includes their wives unmarried daughters and adopted children . A daughter on

2
marriage ceases to be a member of her father's family and becomes a member of husband's
family.

In Surjit Lal v. Common. I.T.,2 the Supreme Court elaborates that outside the limits of
coparcenary, there is a fringe of person males and females, who constitute an undivided
family. There is no limit to the number of persons who compose it, nor to their remoteness

from their common ancestor and to their relationship lineally or laterally with one-another .

To be a member of the family one may be added by birth, marriage or adoption . A female

who comes in the family by marriage becomes sapinda of her husband . The joint family is
thus a larger body consisting of a group of persons who are united by the knot of sapindaship
arising by birth, marriage or adoption.

The general principal is that every Hindu family is presumed to be joint unless the contrary is
proved, but this presumption can be rebutted by direct evidence or by course of conduct . The

joint and undivided family is the normal feature of Hindu society . There is a presumption in

Hindu law that a family is living in a state of union, unless the contrary is proved .3 The
presumption is stronger in case of nearer relationship but gets weaker in case of remoter
relationship.4

In M. Gowdappa v. Ramachand5, the Supreme Court has held that the burden of proving that
any particular property is joint family property is therefore, in the first instance upon the
person who claims it as coparcenary property. But if the possession of a nucleus of the joint
family property is either admitted or proved, any acquisition made by a member of the joint
family is presumed to the joint family property.

Hindu joint family is not a corporation and it has no legal entity distinct and separate from its
members.6 It is also not a juristic person,7 and is represented by Karta or head of the family in

relation to the affairs of the family in relation to others.

2
Surjit Lal v. Common. I.T., 1976 HLR (SC) 146.
3
Govind Das v. Kuldip Singh, AIR 1971 Del 151
4
V.R. Virupakshaiah v. Sarvamma, AIR 2009 SC 1481.
5
M. Gowdappa v. Ramachandra, AIR 1969 SC 1076.
6
Chotelal v. Jhandelal, AIR 1972 All 424.
7
Ram Kumar v. CIT, AIR 1953 All 150.

3
HINDU WOMEN'S RIGHT TO PROPERTY ACT, 1937
By way of a social reform, the Hindu Women's Right to Property Act, 1937 put the widow of
a member of Mitakshara joint family in the place of her deceased husband and the husband's
interest in the joint family, though un-defined, vested on his death in the widow.8 She became
entitled to receive the coparceners share by statutory substitution and could ask for the
partition but by virtue of Section 3(3) her interest was a limited estate . The provision of
reversion was also present where the property once accorded to the widow, is reverted to the
male heir of the deceased person after the widowed woman dies . The property does not to go

to her legal heirs but to the legal heirs of her deceased husband.

However, the Hindu Succession Act, 1956 has abolished the practice of reversion . Prior to
this Act, on widow's death, the estate reverts to the heirs of the last full owner as if the latter
died when the limited estate ceased. Even though the Act has abolished this discriminatory

practice, still it looks in the background by the impact of Section 15(2) of the Act .
Subsection (1) of Section 14 of the Hindu Succession Act, 1956 has abolished the woman's
limited estate in respect of property not acquired or possessed under a Will, gift, Award,
document or a decree of the Court prescribing limited estate . After passing of the Act of 1956
whatever property is possessed by her in a lawful manner whether acquired before or after
commencement of the Act, becomes her absolute property and she becomes its absolute
owner. But subsection (2) of Section 14 preserves the limited estate, in respect of properties
where a limited estate has been prescribed by the document under which the widow comes
into possession thereof.

8
Section 3(2) of the Hindu Women's Right to Property Act, 1937.

4
CONCEPT OF COPARCENARY

The primary purpose of understanding the concept of Mitakshara coparcenary was spiritual in
nature. A coparcener in relation to the father is a person who can offer a funeral cake to him .
This capability to offer spiritual salvation by the performance of funeral rites was with the
son, son of a son (grandson), and son of a son of a son (great-grand son) and as a
consequence of it they were conferred a right by birth in the property of the father . This
religious aspect that associated it primarily with relationship and spiritual benefits and not
merely from the property perspective was totally side-lined later by the legal aspect . The

revenue authority's view was that coparcenary purely from the property angle . Presently it is
understood to ascertain the rights and obligations of the members in the joint family property
that is also called as ancestral property or the coparcenary property.

A Hindu coparcenary is a much narrower body than the Hindu joint family . It includes only
those persons who acquire by birth an interest in the joint or coparcenary property and these
are the sons, grandsons and great grandsons of the holder of the joint property for the time
being, that is to say, the three generations next to the holder in unbroken male descent.

A coparcenary is purely a creature of law and cannot be created by contract . But the adopted
person may be introduced as a member of the coparcenary 9 and after the death of common
ancestor coparcenary of brother can be created.

Incidents of Coparcenary ship:

Hon'ble Supreme Court has laid down the incidents of coparcenary in the case of Hardeo Rai
Vs. Shakuntala Devi and Ors.,10 and it is held that,

 “The incidents of coparcener ship under the Mitakshara law are:

 First, the lineal male descendants of a person up to the third generation, acquire on
birth ownership in the ancestral properties of such person;

9
Section 12 of the Hindu Adoptions and Maintenance Act, 1956.
10
Hardeo Rai Vs. Shakuntala Devi and Ors., AIR 2008 SC 2489.

5
  Secondly that such descendants can at any time work out their rights by asking for
partition;
 Thirdly that till partition each member has got ownership extending over the entire
property conjointly with the rest;
 Fourthly, that as a result of such co-ownership the possession and enjoyment of the
properties is common;
 Fifthly, that no alienation of the property is possible unless it be for necessity, without
the concurrence of the coparceners, and
 Sixthly, that the interest of a deceased member lapses on his death to the survivors.”

The most important of the coparcenary is that a female cannot be a coparcener under
Mitakshara School. Even a wife, though she is entitled to maintenance out of her husband's
property, and has to that extent an interest in his property, is not her husband's coparcener. A
mother is not a coparcener with her son. There can be no coparcenary in between a mother
and a daughter. While considering the position of a woman in the family, a reference must
also go to the concept of streedhana. It can be described thus, “a property which was given by
the father, mother, husband or by a brother at the time of wedding before the nuptial fire and
a gift.”11 Streedhana is the absolute property of a woman and she may dispose of at her
pleasure.

The position of a female member in the joint Hindu family was minimal in nature. She had no
independent rights and was mostly dependant on the male counterparts of the family. She had
no absolute rights in the joint family much less in the coparcenary, wherein she was not even
recognized.

11
Standish Grove Grady, A Manual of Hindu Law, Congress, 1871, London.

6
DISCTINCTION BETWEEN JOINT HINDU FAMILY AND
HINDU COPARCENARY

A Hindu coparcenary is distinct from a Hindu undivided family . There are two schools of

Hindu law, the Mitakshara and Dayabhaga. A Hindu coparcenary is a special feature of
Mitakshara law and there is a clear distinction between a joint family and a Hindu
coparcenary. As observed by the Supreme Court in Surjit Lal v . V. CIT,12 a Hindu

coparcenary is a much narrower body than the joint family . The main points of distinction
between these are that joint Hindu family consists of all persons lineally descended from a
common ancestor and includes their wives and unmarried daughters . On the other side, all
those members of the joint family who get an interest by birth in the joint family property are
the members of the coparcenary.13 The Mitakshara School entitles a son to a right equal to his

father in the joint family property by birth. Under the Hindu law the word "son" has a

technical meaning. Son includes the son, the son's son and the son's son's son . Coparcenary
commences with a common ancestor and includes a holder of joint property and only those
males in his line who are not removed from him by more than three degrees . The daughter

was not given a right by birth in the joint family property.

Both the concepts of "Mitakshara Coparcenary Property" and "Hindu joint family property"
are often mistaken for each other. There may be some degree of overlapping between the

two, but yet they are distinct from each other in some respect . The issue of their

differentiation has come into focus in Hardev Rai v. Shakuntala Devi and Others14 where, the
appellant and the respondent's father entered into an agreement for the sale of some
immovable property.

12
Surjit Lal v. V. CIT, AIR 1976 SC 109.
13
State of Maharashtra v. Narayan Rao (1985) 2 SCC 321.
14
Hardev Rai v. Shakuntala Devi and Others, AIR 2008 SC 2489.

7
ROLE OF SURVIVORSHIP
In the classical words of Lord Westbury in the well-known case of Appovier v. Rama
Subbayyan,15 "according to the true notion of an undivided family in Hindu law, no
individual member of that family, while it remains undivided property, that particular
member, has a certain definite share."

He has an interest in the coparcenary and on his death, this interest lapses to the coparcenary;
it passes by survivorship to the other coparceners . He, therefore, has no power to devise it by

Will, nor is there any question of succession to it . In no part, of the coparcenary property has

he left an ‘estate’ of his own.

In other words, survivorship consists in the exclusion of the widows and other heirs of the
coparcener from succeeding to his undivided interest in the coparcenary property . Even a
disqualified person is a member of the coparcenary and even though he has no rights at a
family partition, he is entitled, when he becomes the last surviving male member of the joint
family, to take and enjoy the whole estate by survivorship.16

However, the Hindu Women's Right to Property Act, 1937 makes a serious inroad upon this
rule of survivorship for the interests of male coparceners in a Mitakshara family by providing
to this share devolve on their death, upon their widows as for a Hindu woman's estate which
they are entitled to work out by partition.

15
Appovier v. Rama Subbayyan, (1866) II MIA 75.
16
Muthuswami Gurukkal v. Meenammal, (1919) 43 Mad 664.

8
 RIGHTS OF WOMEN

A coparcenary was a creature of law and could not be created by agreement except that a
male could be inducted by way of adoption . No female could be a coparcener . A female
member of the family might be lineal descendant being daughter, granddaughter or great
granddaughter but was not considered as coparcener and did not acquire any right in the joint
Hindu family property by birth as compared to male members.

In the Vedic times, the head of the family had absolute control over the family property and
partition of the property was unknown. With the flux of time, due to industrialization and
urbanisation the coparceners started going out for employment and individual families came
into existence where the coparceners could retain the property which they earned with their
own skill and exertion even if they were given a specialised training at the cost of the family .
As a result, individual property and women's property emerged and gradually expanded in
scope and interest but the Hindu family continued to be joint and did not disintegrate into
individual families.

Under the traditional Hindu law, no female could be a coparcener though they were included
in the joint family and were given certain proprietary rights, yet they did not have many
rights vis-a-vis men and their position had been somewhat inferior as compared to their male
counterparts, since times immemorial. They acquired no interest by birth and were not
entitled to claim partition but some females were entitled to a share when partition took place
by metes and bounds.17

Under Mitakshara School there are certain female who are entitled to get a share on partition
but there share was again in form of limited estate i.e. during their life time. After the death
of these female the estate reverts back to the reversioners of last male owners, these are
father's wife, mother, grandmother and the daughter . The women under the Mitakshara
School also have the right and the authority to claim streedhan, whose literal meaning is
women's property. The Mitakshara and the authorities that follow it, take the term
'Streedhana' in its etymological sense and includes all kinds of property of which a woman

17
Basant K. Sharma (Dr.), Hindu Law, Central Law Publications; 4th Ed. 2014, New Delhi.

9
has become the owner, whatever may be the extent of her rights over it. However, there also

exists lack of control over the property. Though the property is that of the woman, she still

cannot dispose it off, her control over the property is limited by that of her husband.

A widow of a deceased coparcener could not be treated as coparcener and could not be a
Karta of the family. An alienation made by her would not be binding on the other members

except to the extent of her share.18 Though a female could not act as manager or Karta of an
undivided Hindu family as she was not a coparcener but she could be taken as a manager for
the purpose of the Income Tax Act, 1961 representing the family.19

Though the Hindu Succession Act was passed with main objective of ameliorating and to
enhance the women’s economic position, but the real problem began when it is going to be
applied in reality. Since the question of woman’s inheritance rights are concerned with
immovable property, especially land, and our patriarchal structure does not allow women to
inherit the landed property. Even our customs (excluding, of course matrilineal customary

law) tend to limit women’s property only up to the movable contents e .g. ornaments and

clothing actually given to them at the time of marriage . Sometimes these customs allow them
to inherit from very near relation like the father and mother or some time from the mother
only otherwise it denies the right of inheritance to cognate kindred.20

WOMEN PROPERTY RIGHTS AND THE STATUTORY LAWS

The Code of Gentoo Laws is the first example of codified Hindu personal laws. In 1772, this
was formulated by a group of 11 pandits, under guidance of Warren Hastings, to compile a
code in Hindu Laws. This helped create an illusion that formulation of laws was still in the
hands of Brahmins, and therefore, the role of women in the legislation as well as in the
inheritance and succession was very much limited. The next round of modifications was
carried out 20 years later where the final Digest of Hindu Law was compiled by H.T.
Colebrooks.

18
Kanji v. Permanand, AIR 1992 MP 208.
19
Surjitlal v. CIT, AIR 1976 SC 109.
20
J. Dancan. M. Derret, A Critique of Modern Hindu Law, N. M Tripathi Pvt. Ltd, Bombay (1970), p. 193.

10
The Caste Disability Removal act of 1850, Hindu Wills Act of 1870, The Hindu Inheritance
(Removal of Disabilities) Act, 1928 along with the Indian Succession Act, 1925 which now
governs the testamentary succession among Hindus, were the attempts made the legislature to
govern the property rights in India, however, none of these provided property rights to
women. The Hindu Married Women's Right to Separate Residence and Maintenance Act,
1946 provided enactment involving certain rights in Hindu married woman to claim separate
residence and maintenance in given circumstances.

The first major legislation in this regard was The Hindu Law of Inheritance (Amendment)
Act, 1929, according to which a son's daughter, daughter's daughter, sister and sister's son "
shall in that order, be entitled to rank in the order of succession next after the paternal
grandfather and before the paternal uncle." The Act has also made it clear that it did not
affect the nature of the estate taken by the female heirs according to the school concerned nor
enabled more than one person to succeed where, by a customary or 56 other rule of
succession, a single person could succeed . This Act has been replaced by the Hindu

Succession Act, 1956.

Next was The Hindu Women's Right to Property Act, 1937. In order to confer more better
and significant inheritance rights to the women, this Act was passed to amend the Hindu law
of succession of all schools. It made innovative changes in the Mitakshara law . In fact, it

affected the law of coparcenary, partition, alienation and succession. It conferred upon the
widow of a man, whether governed by the Mitakshara or the Dayabhaga law, right to
inheritance to the property even when he dies leaving behind a male issue . Similar rights
were conferred upon the widows of his pre-deceased son and the widow of pre-deceased son
of a pre-deceased son. After this Act, in the Mitakshara undivided family the widow of a

deceased coparcener was entitled to take his interest in the joint family . In all cases, widows

were entitled to claim partition. All the females took a limited estate.

By the Act of 1937 new rights of inheritance have been conferred on her and she had been
given the right to inherit her deceased husband's property in the same manner as the son . In
other words, the Act has made her co-heir with the sons and entitled her to inherit in her
husband's property the same share as that of a son. In the case of more than one widow, the

11
Act together gave them a share equal to that of a son. Similar rights were conferred on the

widow of a predeceased son and the widow of a predeceased son of a predeceased son.

These are some of the instances, which show attempts of law makers in the pro-independence
era to codify the vast and vivid Hindu Law. But these attempts were not enough to recognize
the rights of the female Hindu in a family. Even after these enactments a female Hindu had
no independent and substantial rights barring few or to say fewer instances provided under
the above mentioned codified parts. They had minimal impact in uplifting the basic women's
right in the family. Post-independence era did witness major overhaul in the system. While
considering the rights of women, a reference to Article 14, 15 and 16 of the Constitution of
India is a must and crucial. Article 14 guarantees equality before law and equal protection of
the law. Article 15 prohibits the discrimination on the ground of religion, race, caste, sex and
place of birth. Article 16 as well guarantees equality of opportunity and prohibits
discrimination in matters of employment. Still there was something missing and that came
with certain major enactments.

The Hindu Succession Act, 1956, this act was enacted after the recommendations of the Rau
Committee in the year 1941. By the Hindu Succession Act of 1956 the two separate systems
of inheritance to the property of a Hindu male prevailed under the Mitakshara and Dayabhaga
Law have been abolished and a uniform system comes into operation as propounded in
Section 8.

The Hindu women's limited estate is abolished and any property possessed by a female Hindu
howsoever acquired is now held by her as her absolute property and she has full power to
deal with it or dispose off it by will as she likes . Section 14 of the Act has one of the path
breaking provision, whereby the female Hindu was given the absolute ownership in the
property acquired before or after the commencement of this Act. Any movable or immovable
property acquired by a female Hindu by inheritance or partition or in lieu of maintenance or
by Gift or by her own skill or in any other manner was included in the scope of this section.
The rights of female Hindu were tried to be recognized by this effort. Hon'ble Supreme Court
in the case of V. Tulasamma vs. Sesha Reddy,21 held that, a Hindu widow is entitled to
maintenance out of her deceased husband's estate irrespective whether that estate may be in

21
V. Tulasamma vs. Sesha Reddy, AIR 1977 SC1944.

12
the hands of male issues or coparceners. She can follow the estate for her right of
maintenance, even if it is in the hands of third person having notice of her rights.

However there still existed a lacuna in the law as the act, when enacted did not recognise a
female Hindu as a coparcener nor does it give right to partition the property. Section 23 of the
act put an embargo on the rights of the Hindu female to claim partition in the dwelling house,
until the male heirs choose their respective shares. She was also given a right in the dwelling
house, whether she is married or not, or is a widow.

Post the enactment of the Hindu Succession Act, five states namely, Maharashtra, Andhra
Pradesh, Tamil Nadu, Kerala and Karnataka, amended the act granting a Hindu female a right
to coparcenary and others rights which had been curtailed by the Act. However, even in these
amendments the rights of married daughters were not fully recognised.

Realising the dichotomy and the gender discrimination due to which a female Hindu was left
devoid of any property, the Law Commission of India undertook the study of the Provisions
of the codified Hindu law with regard to the law of inheritance and the right of daughters.
The Law Commission of India submitted its report on 5 th May 2000, and while
acknowledging the pervasive discrimination against women in Indian socio-economic
conditions, provided a series of reforms to curb this menace.

Keeping this background in mind, the Hindu Succession Amendment Act, 2005 was enacted
to enlarge the rights of a daughter, married and unmarried both and to bring her at par with a
son or any male member of a joint Hindu family governed by the Mitakshara law. It also
sought to bring the female line of descent at an equal level with the male line of descent,
including children of predeceased daughter of predeceased daughter. By the way of the
Amendment Act, the daughter of a coparcener has been admitted in coparcenary and after
the commencement of the Amendment Act, the daughter is a coparcener in her own right.
The daughter now has the same rights and liabilities in the coparcenary property as the son.
This means that a daughter along with a son is liable for debts of joint family. The daughter is
also entitled to dispose of her share of the coparcenary property or her interest thereof by way
of a will.

13
Post the 2005 Amendment to the Hindu Succession Act,

 Daughter is also included as a simultaneous heir along with son, widow, etc.

 The share of daughter in the property of the father is made equal to that of a son.
 Married and unmarried daughters are placed on the same footing and both are the
heirs to the father's property equally along with the other heirs.
 Under section 6 of the Act provision is made to provide a share to the daughter in
Mitakshara coparcenary property of a Hindu male also. The daughter of a coparcener
will become a coparcener in her own right as that of the son
 Elimination of all widows of gotrajas from heirs specified in Class II of the Schedule
except the father's widow and brother's widow.

 Providing the right of pre-emption.22

To sum up, it can be said that all these legislations concerning marriage, succession,
adoption, maintenance and guardianship has promoted the level of emancipation of women to
a very large extent. However, still, there is a hindrance on women’s progress. Gender equality
regarding the property rights will be possible only when the provisions for the constitutional
equality are taken into realization by the people and followed it in its truest sense and spirit.
Status of women in matters of property was recognized partially only under ancient and
medieval conditions. But in times of social emancipation and equality, the pressing necessity
is that in matters of succession there should be equitable distribution between male and
female heirs not only in legal sense but also in the sociological and economical sense.

22
T.P Gopalkrishanan, R.B Sethi and C.Unikanta Menona, Codified Hindu Law, Law Book Company,
Allahabad (1959), p. 9

14
 CONCLUSION

The Amendment of Hindu Succession Act of 1956 in 2005 is a total commitment for the
women empowerment and provides more and more property rights to women in the
Mitakshara system which was mainly patriarchal one. Making daughters as a member of
coparcenary and giving them equal rights as other male coparceners is indeed a very bold
step to provide new arena of rights to females, but one question remains there: whether these
females actually get their share in joint family property? Or does under the social pressures
and our social set up these rights were not at all exercised by females and these things remain
only in our statutes and lastly that in spite of such like amendments . Whether our male
counterparts accept these changes or they evolve the other measures which directly by pass
the law in their own favour?

15
 BIBLIOGRAPHY

BOOKS
 Agarwala R.K. - “Hindu Law”, 21st edn. 2003, Central Law Agency, Allahabad

 B.M. Gandhi- “Hindu Law”, 3rd edn. 2008, Eastern Book Company, Lucknow.

 Dr. Paras Diwan on Hindu Law, 2nd edn. 2005, Orient Publishing Company,

Allahaabad.

 Dr. Paras Diwan- “Modern Hindu Law”, 18th edn. 2007, Allahabad Law Agency,

Faridabad (Haryana).

 Subba Rao, G.C.V. - “Family Law in India”, 8th edn. 2005, S.Gogia & Company,

Hyderabad.

ARTICLES

 "A Hindu Joint Family Setup." LawTeacher. LawTeacher.net, November 2013. Web.

10 March 2020. <https://www.lawteacher.net/free-law-essays/indian-law/a-hindu-

joint-family-setup.php?vref=1>

 Dr. Poonam Pradhan Saxena, Lexis Nexis Student Series Family Law II, 3rd ed. 2012,

pg. 77..

 “JOINT HINDU FAMILY”; Available at: https://www.legalbites.in/joint-hindu-

family/

16