NATIONAL LAW INSITUTE UNIVERSITY, BHOPAL

A PROJECT OF FAMILY LAW-II

ON

AN ANALYSIS OF SEC.14 OF HSA, 1956

SUBMITTED TO: SUBMITTED BY:

Mrs. Kavita Singh Siddharth Vishwakarma

Assistant Professor 2018BALLB28

 TABLE OF CONTENT

Contents
CERTIFICATE ..................................................................................................... 3
ACKNOWLEGMENT.......................................................................................... 4
INTRODUCTION ................................................................................................ 5
STATEMENT OF PROBLEM ............................................................................. 7
RESEARCH QUESTIONS .................................................................................. 7
RESEARCH OBJECTIVES ................................................................................. 7
HYPOTHESIS ...................................................................................................... 7
REVIEW OF LITERATURE ............................................................................... 8
SCOPE AND AMBIT OF SEC.14 ....................................................................... 8
POSSESSION ....................................................................................................... 9
ALIENATION OF THE LIMITED ESTATE BY THE LIMITED OWNER
BEFORE COMMENCEMENT OF ACT: ........................................................... 9
KINDS OF WOMENS PROPERTY .................................................................. 11
Powers of A Hindu Female Over Her Woman’s Estate ..................................... 13
SOURCES OF WOMAN’S PROPERTY .......................................................... 15
CONCLUSION ................................................................................................... 18
 CERTIFICATE

This is to certify that the research paper titled “An Analysis of Sec.14 of HSA,1956”, has
been prepared and submitted by Siddharth Vishwakarma, who is currently pursuing his B.A.
L.L.B. (Hons.) at National Law Institute University, Bhopal in fulfilment of Family Law–
II Course. It is also certified that this is his original research report and this paper has not
been submitted to any other University, nor published in any journal.

Date: ………………..

Signature of the Student: ……………………….

 ACKNOWLEGMENT

This paper has been made possible by the unconditional support of many people. I would
like to acknowledge and extend my heartfelt gratitude to Mrs. Kavita Singh for guiding me
throughout the development of this paper into a coherent whole by providing helpful insights
and sharing her brilliant expertise. I would also like to thank the officials of the National
Law Institute University, NLIU for helping me to find the appropriate research material for
this study. I am deeply indebted to my parents, seniors and friends for all the moral support
and encouragement.

Siddharth Vishwakarma
 INTRODUCTION

Prior to 1956, two kinds of properties were recognized by Hindu texts and writings with
respect to women – Stridhana and non-Stridhana properties.

Stridhana Property:

It occupies a prominent place in the Sanskrit law books that had been written in ancient India.
Etymologically, Stridhana means female’s property. It includes gifts given to her at the time
of marriage. About ownership of Stridhana property, several views existed. Doctrinal
Diversity existed on the subject and these divergent outlooks only added to the difficulties
surrounding the meaning of the term. The result was that, a term not difficult to understand in
its etymological sense came to be understood in a narrow and limited connotation.1

Stridhana is the property over which a woman has absolute right. A Stridhana property has
two important characteristics-

• She could dispose it off as per her sweet will in whatsoever manner;
• It’s her exclusive and absolute property and would devolve upon her heir.

By virtue of Stridhana she would be a fresh stock of descent and her property will not go
back to the reversioners.

Non-Stridhana Property:

The woman at her wish could not dispose off this property. It could not go to her heirs at her
death but would go back to the reversioners. This property is called woman’s estate or a
widow’s estate.

Under the classical law, non-Stridhana property was property acquired by her in any way.
But Stridhana property was in form of gifts at the time of her wedding. With respect to
woman’s estate, she was not a fresh stock of descent. She had limited interests. Though she
could enjoy the property during her lifetime, she had limited rights over it. She could not
alienate the property at her own sweet will nor could dispose it off. It is a limited estate.
When the woman’s limited estate expires upon her death it would revert to the reversioners
that were the heirs of the last male holder of the property.

1
Mulla, Hindu Law, Vol.2, 19th Ed., LexisNexis Butterworths, 2005, P.378
In her lifetime, she had an ownership, title and interest in the property but it was limited. So,
absolute rights lacked.

Limited estate entails two limitations:

• No alienation or disposal of the property at woman’s own discretion;

• No creation of fresh stock of descent.

Under very special circumstances, a woman could alienate her limited estate:

• Legal necessity (that is, for her own need and for the need of the dependants of the
last owner);
• For the benefit of estate, and;
• For the discharge of indispensable duties (such as marriage of daughters, funeral rites
of her husband, his Shraddha and gifts to Brahmans for the salvation of his soul, etc.)

Hindu women have always suffered with respect to property rights. She had an absolute right
over the Stridhana but with respect to non-Stridhana property her interests were not absolute
in nature. Though she had maintenance rights; recognized by law as moral, spiritual, legal
and absolute right, but not beyond that.

Section 14 brought about revolutionary changes in the law of succession with regard to Hindu
females. Section 14 has converted existing woman’s estates into full estates.

Section14:

Property of a female Hindu to be her absolute property.

1. Any property possessed by a female Hindu, whether acquired before or after the
commencement of this Act, shall be held by her as full owner thereof and not as a
limited owner.

Explanation: In this sub-section, “property” includes both movable and immovable property
acquired by a female Hindu by inheritance or devise, or at a partition, or in lieu of
maintenance or arrears of maintenance, or by gift from any person, whether a relative or not,
before, at or after her marriage, or by her own skill or exertion, or by purchase or by
prescription, or in any other manner whatsoever, and also any such property held by her as
Stridhana immediately before the commencement of this Act.
 2. Nothing contained in sub-section (1) shall apply to any property acquired by way of
gift or under a will or any other instrument or under a decree or order of a civil court
or under an award where the terms of the gift, will or other instrument or the decree,
order or award prescribe a restricted estate in such property.

STATEMENT OF PROBLEM
Section 14 talks about property possessed by a Hindu female to be her absolute property,
whether acquired before of after the commencement of the Hindu Succession Act, 1956. She
will hold the property as an absolute, full owner and not as a limited owner. The section
empowers the Hindu female to exercise her rights over her property in an absolute manner.
Section 14 is the most significant provision in the Hindu Succession Act.

RESEARCH QUESTIONS
1. If a Women gets a property in lieu of partition, will it be considered her absolute
property?
2. What are the various powers that Hindu female holds over her estate?
3. Can women claim ownership of mutated property under section 14 of HAS,1956?

RESEARCH OBJECTIVES
1. The Researcher tends to find the ambit of section 14 of HAS,1956
2. The Researcher tends to find the difference between Stridhana and Non-Stridhana
property.
3. The Researcher tends to understand the literal meaning of the word ‘possession’
through various case laws.

HYPOTHESIS
The researcher presumes that there prevails an inequality between male and female
member of family in concept of absolute ownership.
 REVIEW OF LITERATURE
Books involved:
• Diwan Paras, Family Law ,6th edn, Allahabad Law Agency, Faridabad 2003

• Desai A. Satyajeet, Mulla Hindu Law, 17th edn , Butterworths India, Delhi,2000

Cases Discussed:

• Janki v. Narayansami2: The Privy Council aptly observed, “her right is of

the nature of right of property, her position is that of the owner, her powers in
that character are, however limited… So long as she is alive, no one has
vested interest in the succession.”
• Chinnappa Govinda v. Valliammal3: The Court held that she need not
surrender the properties held by her under the maintenance deed.

Scope and Ambit of Section 14

Section 14(1) is partly prospective and partly retrospective. Prospective operation is that
limited interest enlarges only in 1956 and after it. With respect to acquisition of property,
there is retrospective operation.

“Any property possessed by a female Hindu, whether acquired before or after the
commencement of this Act, shall be held by her as full owner thereof and not as a limited
owner.”

The rule laid down under section 14(1) has a wide and extensive application and must be read
in a comprehensive manner. If a woman had a limited interest in any estate, as soon as this
Act comes into force, the limited estate enlarges to absolute interest. She has full ownership
of property acquired before or after 1956.

Section 14(1) is an enabling clause; limited estate converts into absolute one.

2
(1906)43 IA 87
3
AIR 1967 Mad
The object of sub-section (2) of section 14 is to make it clear that restricted estate can even
after commencement of Act come into existence in case of interest of property given to a
female Hindu, by operation of transaction inter vivos, by testamentary disposition, by decree
or order of civil court under an award. Any such restricted estate created prior to the
commencement of the Act will not be enlarged into full ownership by operation of sub-
section (1) if the gift, will, other instrument, decree, order or award had prescribed a
restricted estate. It has been held by Supreme Court that this sub-section (2) must be read
only as a proviso or exception to sub-section (1).4

POSSESSION

Under Section 14, possession implies a lawful and legal possession or title or ownership.
Hence, possession here implies ownership or title. There is the widest possible interpretation
to this term. In 1956, this Act came into force and irrespective of whether she had actual
possession or not, he rights were absolute.

In 1959, in the case Gummalapura Kothuruswami v. Setra Veeravva5, the word possession
was interpreted. Court said here that “possession in section 14 is used in a broad
sense…possession may be actual or constructive…”

In 2002, in the case Muthuswami v. Angamal, distinction between legal and actual possession
was laid down. Under Section 14(1), it is the legal possession that is important. It is not the
possession in its narrow sense but the broadest. There must be a legal possession though there
is not any actual possession. Under Section 14 (1) possession must be lawful and legal.
Where a woman has lost possession of property before commencement of Hindu Succession
Act, 1956, she is not entitled to avail benefits of Section 14(1).

ALIENATION OF THE LIMITED ESTATE BY THE LIMITED OWNER

BEFORE COMMENCEMENT OF ACT:

Before 1956, A Hindu female had a limited estate. There was no alienation at her sweet will.
Where a Hindu woman makes an unauthorized alienation before 1956, she loses possession
over that property, she is not entitled to benefits of Section 14(1). The alienee, even he or she

4
Supra 1
5
AIR 1959 SC 577
cannot avail Section 14(1). Now the possession of property does not allow alienee to avail
this subsection.

To avail benefits of Section 14(1), the possession must be a legal possession.

The alienee here cannot avail provision of Section 14 because it was the widow who made
the alienation. Purpose of section 14 is to ameliorate the position of widow and not the
alienee. Both the woman and the alienee are devoid of the benefit of s.14 (1) and the third
party, i.e. the reversioners will be benefited.

Where alienation is unauthorized reversioners can always challenge. There was a prospective
abolition of reversioners after 1956. But reversioners do exist after 1956. On the death of the
female owner the estate reverts to the heir or the heirs of the last owner as if the latter died
when the limited estate ceased. Such heirs may be male or female known as reversioners. So
long as the estate endures there are no reversioners though there is always a presumptive
reversioner who has only a spes successionis in the lifetime of the widow. It is their vested
interest. The property of the female devolves on the reversioners only when her estate
terminates on her death.

REMEDIES WITH THE REVERSIONERS

1. They can file a suit in the court for a ‘declaratory decree’ under which the reversionary
rights are protected. So, despite unauthorized alienation, their reversionary rights are
secure.
2. They can demand from the court during the lifetime of the widow, that estate of the
widow must be protected from damage or waste.

But reversioners cannot bring any injunction to refrain a widow from making an unauthorized
alienation. When a Hindu widow makes an unauthorized alienation, it is binding upon her
and not on the reversioners. Estate is in favour of the widow or the alienor; it is binding upon
her. Now alienee is entitled to all the rights which alienor was enjoying by alienation. But
alienee gets a limited title.

After unauthorized alienation, the limited estate has passed to the alienee – who has a limited
interest in it. Because a Hindu woman cannot convey a better title than what she had, the
alienee will also have a limited interest in the estate. When the alienor dies, i.e. the widow,
the role of reversioners accrues.
In the case of Kalawati Bai v. Soirya Bai 6,a Hindu female had inherited property from her
husband by way of gift. In 1954, she gifted entire property to one of her two daughters. In
1968, the Hindu widow died and have a daughter, in whose favour the gift was made, took
possession of the property. The second daughter objected this possession arguing that
alienation was an unauthorized alienation. Since, the alienation itself is unauthorized, the
daughter does not have any right to possess the property. It was held that the other daughter
would get half of the share from the entire property. After the death of the widow, the
property goes back to reversioners, i.e. the heirs of the last male holder of the property. After
widow’s death, it will be presumed that her husband had died too. Since in 1968, the Act
came into force; the two daughters will get equal half shares.

KINDS OF WOMENS PROPERTY

What is the character of property that is whether it is stridhan or woman’s estate, depends on
the source from which it has been obtained? They are:

• Gifts and bequests from relations- Such gifts may be made to woman during
maidenhood, coverture or widowhood by her parents and their relations or by the
husband and his relation. Such gifts may be inter vivos or by will. The Dayabhaga
School doesn’t recognize gifts of immovable property by husband as stridhan.
• Gifts and bequests from non-relations- Property received by way of gift inter
vivos or under a will of strangers that is, other than relations, to a woman, during
maidenhood or widowhood constitutes her stridhan. The same is the position of gifts
given to a woman by strangers before the nuptial fire or at the bridal procession.
Property given to a woman by a gift inter vivos or bequeathed to her by her strangers
during coverture is stridhan according to Bombay, Banaras and Madras schools.
• Property acquired by self-exertion, science and arts-A woman may acquire
property at any stage of her life by her own self exertion such as by manual labour,
by employment, by singing, dancing etc., or by any mechanical art. According to all
schools of Hindu Law, the property thus acquired during widowhood or maidenhood
is her stridhan. But, the property thus acquired during coverture does not constitute
her stridhan according to Mithila and Bengal Schools, but according to the rest of the
schools it is stridhan. During husband’s lifetime, it is subject to his control.

6
AIR 1991 SC 1581
• Property purchased with the income of stridhan- In all schools of Hindu Law it is
a well settled law that the properties purchased with stridhan or with the savings of
stridhan as well as all accumulations and savings of the income of stridhan,
constitute stridhan.
• Property purchased under a compromise- When a person acquires property
under a compromise; what estate he will take in it, depends upon the compromise
deed. In Hindu Law, there is no presumption that a woman who obtains property
under a compromise takes it as a limited estate. Property obtained by a woman under
a compromise where under she gives up her rights, will be her stridhan. When she
obtains some property under a family arrangement, whether she gets a stridhan or
woman’s estate will depend upon the terms of the family arrangement.
• Property obtained by adverse possession- Any property acquired by a woman at
any stage of her life by adverse possession is her stridhan.
• Property obtained in lieu of maintenance- Under all the schools of Hindu Law
payments made to a Hindu female in lump sum or periodically for her maintenance
and all the arrears of such maintenance constitute stridhan. Similarly, all movable or
immovable properties transferred to her by way of an absolute gift in lieu of
maintenance constitute her stridhan.
• Property received in inheritance- A Hindu female may inherit property from a
male or a female; from her parent’s side or from husband’s side. The Mitakshara
constituted all inherited property a stridhan, while the Privy Council held such
property as woman’s estate.
• Property obtained on partition- When a partition takes place except in Madras,
father’s wife mother and grandmother take a share in the joint family property. In the
Mitakshara jurisdiction, including Bombay and the Dayabhaga school it is an
established view that the share obtained on partition is not stridhan but woman’s
estate.
Stridhan has all the characteristics of absolute ownership of property. The stridhan
being her absolute property, the female has full rights of its alienation. This means
that she can sell, gift, mortgage, lease, and exchange her property. This is entirely
true when she is a maiden or a widow. Some restrictions were recognised on her
power of alienation, if she were a married woman. For a married woman stridhan
falls under two heads:
 • the sauadayika (gifts of love and affection)- gifts received by a woman from
relations on both sides (parents and husband).
• the non-sauadayika- all other types of stridhan such as gifts from stranger,
property acquired by self-exertion or mechanical art.

Over the former she has full rights of disposal but over the latter she has no right of
alienation without the consent of her husband. The husband also had the power to
use it. On her death, all types of stridhan passed to her own heirs. In other words, she
constituted an independent stock of descent. In Janki v. Narayansami7, the Privy
Council aptly observed, “her right is of the nature of right of property, her position is
that of the owner, her powers in that character are, however limited… So long as she
is alive, no one has vested interest in the succession.”

Powers of A Hindu Female Over Her Woman’s Estate

a) Power of Management- like the Karta of a Hindu joint family she has full power of
management. The Karta is merely a co-owner of the joint family, there being other
coparceners, but she is the sole owner. She alone is entitled to the possession of the entire
estate and its income. Her power of spending the income is absolute. She need not save and
if she saves, it will be her stridhan. She alone can sue on behalf of the estate and she alone
can be sued in respect of it8. Any alienation made by her proper or improper is valid and
binding so long as she lives. She continues to be its owner until the forfeiture of estate by
her re-marriage, adoption, death or surrender.
b) Power of Alienation- She has limited powers of alienation, Like Karta her powers are
limited and she can alienate property only in exceptional cases. She can alienate the
property for the following:
• Legal necessity (i.e. for her own need and for the need of the dependants of
the last owner)
• For the benefit of estate, and

7
(1906)43 IA 87
8
Sitaji v. Bijendra AIR 1964 SC 601
 • For the discharge of indispensable duties (such as marriage of daughters,
funeral rites of her husband, his shradha and gifts to Brahmans for the
salvation of his soul; that is, she can alienate her estate for the spiritual benefit
of the last owner, but not for her own spiritual benefit.)

Under the first two heads her powers are more or less the same as that of the Karta.
Restrictions on her powers of alienation are an incident of the estate and not for the benefit of
the reversioners.5 As to the power of alienation under the third head, a distinction is made
between the indispensable duties for which the entire property could be alienated, and the
pious and charitable purposes for which only small portion of property can be alienated. She
can make alienation for religious acts, which are not essential or obligatory but are still pious
observances which conduce to the bliss of her deceased husband’s soul.9

c) Surrender- means renunciation of estate by the female owner. She has the power of
renouncing the estate in favour of the nearest reversioner. This means that by a
voluntary act she can accelerate the estate of the reversioner by conveying absolutely
the estate thereby destroying her own estate. This is an act of self-effacement on her
part and operates as her civil death. For a valid surrender, the first condition is that it
must be of the entire estate, though she may retain a small portion of her maintenance.
The second condition is that it must be in favour of the nearest reversioner or
reversioners, in case there are more than one of the same category. Surrender can be
made in favour of female reversioners also. The third condition is that the surrender
must be bonafide and not a device of dividing the estate with the reversioners.
d) Reversioners- On the death of the female owner the estate reverts to the heir or the
heirs of the last owner as if the latter died when the limited estate ceased. Such heirs
may be male or female known as reversioners. So long as the estate endures there are
no reversioners though there is always a presumptive reversioner who has only a spes
successionis (an exception). The property of the female devolves on the reversioners
when her estate terminates on her death, but it can terminate even during her lifetime
by surrender.
e) Right of Reversioners- the reversioners have a right to prevent the female owner
from using the property wastefully or alienating it improperly. It is this context that

9
Smt. Kamala Devi v. Mukund Ram AIR 1955 SC 481
 the expression “presumptive reversioner” came into vogue.10 The reversioners have
the following three rights:
• They can sue the woman holder for an injunction to restrain waste.
• They can in a representative capacity sue for a declaration that alienation made by
the widow is null and void and will not be binding on them after the death of the
widow. However, by such a declaration the property does not revert to the woman nor
do the reversioners become entitled to it. The alienee can still retain the property so
long as the widow is alive.
• They can after the death of the woman or after the termination of estate, if earlier,
file a suit for declaration that an alienation made by the widow was improper and did
not bind them. The Supreme Court, observed that when a Hindu female holder of
woman’s estate improper makes alienation, the reversioners are not bound to institute
a declaratory suit during the lifetime of the female holder. After the death of the
woman, they can sue the alienee for possession of the estate treating alienation as a
nullity.11

SOURCES OF WOMAN’S PROPERTY

• PROPERTY RECEIVED IN LIEU OF PARTITION- The Karta can grant

some property to a member of the family for his or her maintenance. A Hindu
female can also be granted property for her maintenance under a family
arrangement or a partition. In Chinnappa Govinda v. Valliammal12, a father-
in-law gave some properties for the maintenance of his widowed daughter-in-
law under a maintenance deed. Subsequently, in 1960 he died. Since he died
leaving behind the daughter-in-law his interest devolved by succession. The
daughter-in-law sued for partition so as to get her share of inheritance. Other
members said that she could get her share only if she agreed to include the
properties given to her for maintenance in the suit properties. The Court held
that she need not surrender the properties held by her under the maintenance
deed.

10
Bakshi Ram v. Brij Lal AIR 1995 SC 395
11
Radha Rani Bhargava v. Hanuman Prasad Bhargava AIR 1966 SC 216
12
AIR 1969 Mad 187
 Section 14 lays down that any property which a Hindu female gets on partition after
the commencement of the Act will be her absolute property and any property which
she got at a partition before the commencement of the Act will also become her
absolute property provided it was in her possession at the commencement of the Act.
The Kerala High Court in Pachi Krishnamma v. Kumaran Krishnan13 observed
that the share a woman got on partition would be her absolute property on account of
her pre-existing right to maintenance enlarged to an absolute title to property by virtue
of section 14(1).”

• PROPERTY GIVEN UNDER AN AWARD OR DECREE- In Badri

Prasad v. Kanso Devi14 where a partition under an award was subsequently
embodied in a decree, certain properties were allotted to a Hindu female as her
share, the Supreme Court said that section 14(2) did not apply. Their
Lordships said that section 14 should be read as a whole. It would depend on
the facts of each case whether the same is covered by sub-section (1) or
subsection (2). The crucial words in the subsection are ‘possessed’ and
‘acquired’. The former has been used in the widest possible sense and in the
context of section 14(1) it means the state of owning or having in one’s hand
or power. Similarly, the word acquired has also been given widest possible
meaning. The Supreme Court was of the view that a share obtained by a Hindu
female in a partition under section 14(1) even though her share is described as
a limited estate in the decree or award.

• PROPERTY UNDER AN AGREEMENT OR COMPROMISE- The test

that if the decree or award is the recognition of pre-existing right then sub-
section (1) will apply and if property is given to the Hindu female for the first
time under an award or decree subsection (2) will apply. It has been applied to
the acquisition of property under an agreement or compromise. This

13
AIR 1982 Ker 137
14
AIR 1970 SC 1963
 distinction has been clearly brought out by Mahadeo v. Bansraji15 and
Lakshmichand v. Sukhdevi16

• PROPERTY RECEIVED IN INHERITANCE- Any property that a Hindu

female inherited from a male or female relation was taken by her as limited
estate except in the Bombay school. Section 14 lays down that any property
that a Hindu female inherits from any relation after the commencement of the
Act will be her absolute property. On her death, it will devolve on her heirs
under the provisions of section 15 and 16. If any property has been inherited
by her before the commencement of the Act and if it is in her possession then
that property also became her absolute property.

• PROPERTY RECEIVED IN GIFT -Under the Act, there is no distinction

between the gifts received by her from relatives or strangers and at any stage
of her life, and all gifts that she receives will be her absolute property.
Ornaments received by her at the time of her marriage are ordinarily her
stridhan property. A full bench in Vinod Kumar Sethi v. State of Punjab17
held that dowry and traditional presents made to a wife at the time of the
marriage constitute her stridhan. In Gopal Singh v. Dile Ram18, a widow
having a life estate purported to make a gift of the property before the Hindu
Succession Act 1956 came into force.

• PROPERTY RECEIVED UNDER A WILL- In Karmi v. Amru19, A

Hindu under a registered will , conferred a life estate on his wife Nihali , with
the direction that after the death of Nihali , properties would devolve on
Bhagtu and Amru , two of his collaterals Nihali took possession and died in
196. On her death her heirs claimed property on the assertion that after the
coming into force of the Hindu Succession Act, Nihali’s life estate became her
full estate . It was held that where only life estate is conferred under a will ,
Section 14(2) will apply , and the estate will not become full estate .But if a

15
AIR 1971 ALL 515
16
AIR 1970 Raj 285
17
AIR 1982 P& H 372
18
AIR 1987 SC 2394
19
AIR 1971 SC 745
 will confers on her full estate , she will take absolutely . Properties given
under a settlement to the widow which were to revert to the settlor on his
brother on her death, do not get enlarged into full estate.

CONCLUSION

Section 14 of The Hindu Succession Act 1956 has abolished certain women’s estate
and in respect of woman’s estate which are outside the purview of section 14, a
reversioner’s right under old Hindu Law still endures. Section 14(1) has qualified
retrospective application, it converts only those woman’s estates into full estates over
which she has possession when the Act came into force. It does not apply to those
woman’s estates over which the Hindu female has no possession when the Act came
into force; in such a case, old Hindu Law continues to apply. Section 14(2) uses the
words “any other instrument”. Applying the principle of ejusdem generis, these words
should be read along with the preceding words, “acquired by way of gift or under a
will” and would thus, mean the instruments under which title to property has been
conveyed to the Hindu female20.

20
Chinamma v. Lingamma AIR 1972 Mysore 333