Joint Family Property & its Alienation Page |1

Joint Family Property & its

Alienation: Detailed Comment

Aditi1, Sunidhi Wahi2, Aishwarya Raghuram3

1 rd
3 Year Law Student, NMIMS School of Law, Bengaluru
aditi.380@nmims.edu
2
3rd Year Law Student, NMIMS School of Law, Bengaluru
sunidhi.wahii102@nmims.edu.in
3
3rd Year Law Student, NMIMS School of Law, Bengaluru
aishwarya.raghuram158@nmims.edu.in

SAP ID- 181012019380, 2 81012019102, 381012019158

Submitted to- Dr Tanmeet Kaur Shahiwal

NMIMS School of Law, Bengaluru

Joint Family Property & Its Alienation Page |2

Table of Contents
1. Introduction ......................................................................................................4

2. Research Design ................................................................................................5

3. Literature Review .............................................................................................6

4. Analysis ..............................................................................................................8

5. Findings & Suggestions................................................................................... 18

6. Conclusion ....................................................................................................... 19

7. Bibliography .................................................................................................... 20
Joint Family Property & Its Alienation Page |3

Table of Cases

Name of Case Page no.

Beereddy Dasaratharami Reddy v. V. Manjunath 6

Jandhayala Sreeamma v. Krishnavenamma 7

Devulapalli Kameswara Sastri v. Polavarapu 9

Veeracharlu
Palaniappa v. Devsikmony 10
Hari Singh v. Umrao Singh 11
Balmukund v. Kamlawati & Ors 11

Gangi Reddy v. Tammi Reddi 11

Deen Dayal vs. Jagdeep 12

Alluri Venkatapathi Raju vs. Venkatnarasimha Raju 13

R Kuppayee v. Raja Gounder 14

Gauramma v. Mallappa 15

Hasmat v. Sundar 16
Narayan Pd v. Sarmam Singh 16
Joint Family Property & Its Alienation Page |4

1. Introduction
A joint family is a group of blood-related people who live and act as one entity. A Hindu Joint
Family comprises of a common ancestor, his descendants, and his wife. In the Hindu Joint Family
tradition, there are no generation limits. A Hindu Joint Family Property Also Known as
Coparcenary is an ancestral property in which Coparceners hold unity of possession. Coparcenary
is a part of Hindu joint family but only a specific group of people of Hindu joint family can become
coparceners. All the male members of father son & alike relation and daughters are called as
coparceners. Joint family property alienation means transfer of that coparcenary property or in
layman terms setting aside a part of that coparcenary property by sales, gifting, mortgages, etc.

Hindu Succession Act & Transfer of Property act are the statues that deals with Alienation of Joint
Family Property. Earlier only the Karta (Head of Hindu Joint Family) had the right of alienation
but with changing times & laws other coparceners had also been given certain rights to alienate.

This Paper Revolves Around certain set of Questions of which the researchers have tried to find a
detailed answer by the end of the paper. This Research deals with in what ways alienation can be
done, who all can alienate, Rights of the people who can alienate in detail, right of the person to
whom alienation can be done, right of other persons of a coparcenary to challenge a certain
alienation so on & so forth. By the end Finding and Suggestions are provided to conclude.

Keywords: Alienation, Karta, Coparceners, Alienee, Hindu Joint Family, Rights

Joint Family Property & Its Alienation Page |5

2. RESEARCH DESIGN

Research methodology:

This paper employs a doctrinal methodology, and the sources utilized are documentary. Therefore,
the article is based on an analysis of both primary and secondary sources. This comprises, among
other things, statutes, textbooks, case law articles, journals, papers and reports presented at
seminars or workshops, Internet materials, and so forth. Generally, it is used to examine the law
as it is, to establish new conceptions, or to reinterpret current ones.

Problem statement: A Hindu Joint Family constitutes the Karta, other members of the family as
well as fellow coparceners. Alienation is one of few important aspects talked about while studying
for the same. The matter of contention becomes who all have the right to alienate property and
whether the Karta enjoys certain powers over other.

Research question:

(i) What constitutes a Hindu Joint Family?

(ii) Who all can alienate a coparcenary property?
(iii) What and the Rights of Coparceners to challenge an alienation of the joint property?
(iv) What rights and remedies do the Alienee have with respect to the alienation or partition?

Research objective:

The goal of this study is to determine (i) the different ways to alienate a property (ii) to understand
who all possess the right or power to alienate a coparcenary property and (iii) to recognize all the
rights and remedies that are available to the alienee as well as the coparceners with respect to
alienation of the property

Literature Review: Three articles, two papers and one book have been reviewed on this topic.
Joint Family Property & Its Alienation Page |6

3. Literature Review-
The article “Hindu Joint Family and Karta’s Right of Alienation”1 By Pushkar Sinha comments
and provides us a detailed explanation of the Hindu Undivided family, with its main focus being
on the Karta as the manager as well as the coparceners with their right to alienation. The article
aided our paper in the sections mentioning the Coparcener’s right to alienate the property along
with attaching landmark judgements with it. The paper only lacked in the part where they could
have incorporated the sole coparcener’s right of alienation owing to its importance in the main
topic.

The blog titled “Can Karta alienate Joint Hindu family property without coparcener’s
signature”2 by Prachi Bhardwaj gives a brief comment on the recent decided judgement of the
case of Beereddy Dasaratharami Reddy v. V. Manjunath3. This matter of contention was whether
or not the Karta could alienate the property without the signatures of the coparceners, in this case-
the Karta’s own son. The court ruled in favor of the fact that K. Veluswamy being the Karta was
entitled to execute the agreement to sell and even alienate the suit property. Absence of signatures
of V. Manjunath would not matter and is inconsequential.

Dr. Travina Vyas through her works on “Joint Hindu Family Property: Its Investment,
Alienation and Partition”4 mentions Hindu Undivided family property basis the Income tax Act
of 1961. Although majorly focused on taxation and how Hindu Joint family is considered as a
taxable entity, this paper sheds light on the property’s alienation, partition and the Karta, which
helped make arguments based on the same.

1
Pushkar Sinha, “Hindu Joint Family and Karta’s Right of Alienation” 2(2) Indian Journal of Integrated Research
In Law (2020)
2
Prachi Bhardwaj, “Can Karta alienate Joint Hindu family property without coparcener’s signature”, December 14,
2021 available at: https://www.scconline.com/blog/post/2021/12/14/explained-can-karta-alienate-joint-hindu-
family-property-without-coparceners-signature/ (last visited on September 27 2022)
3
C.A. No.-007037-007037 - 2021
4
Dr. Travina Vyas, “Joint Hindu Family Property: Its Investment, Alienation and Partition” 7(1) Indian Journal of
Integrated Research In Law 958(2020)
Joint Family Property & Its Alienation Page |7

Just like the scenario mentioned in the above case brief, the article “Legal necessity as a ground
for Alienation of Joint Family Property”5 by Pooja Shrivastav analyses the Karta’s power to
alienate the property along with the coparcener’s in it. It explains their statement through the case
of Jandhayala Sreeamma v. Krishnavenamma where a suit to set aside an alienation was filed by
the younger of two brothers. Furthermore, it also included the promotion of rights of women to
inherit property through the introduction of the Hindu succession Act, which went into effect on
June 17. Women’s right to inherit property is also an area of interest for this paper.

Gtinther Sontheimer mentioned in his book “The Joint Hindu Family: Its evolution as a legal
institution”6 about how the Indian family institution is founded on the notion that a nucleus of
ancestral property and its accretions does not belong exclusively to one person, but rather serve as
the basis for the spiritual and economic welfare of family members, typically within a circle of
three generations. It talks about the traditional beliefs, and how such a concept was founded on
patriliny. The chapter on the alienation by the manager in modern India help curate opinions and
content for our paper.

Lastly, we looked through the works of Saimy Eliza Abraham and were able to incorporate many
finding from “Short Note on Hindu Joint Family- under Mitakshara and Dayabhaga”. The
paper comments on joint family property and its members while greatly focusing on the rights of
the coparceners. With the help of case laws, it further strengthen the explanation and arguments
based on the topic selected. We were able to incorporate the rights and powers in our research
paper for the same.

5
Pooja Shrivastav, Legal necessity as a ground for Alienation of Joint Family Property (2020) (Unpublished LLB
research work, Chanakya Law Institute)
6
Gtinther Dietz Sontheimer, The Joint Hindu Family: Its evolution as a legal institution 253 (University of Tiibingen,
Germany, 1977)
Joint Family Property & Its Alienation Page |8

4. Analysis

ALIENATION OF JFP

EXPRESS AUHTORITY (exception) IMPLIED/JUDICIAL AUTHORITY

Consent coparcenary legal necessity benefit of estate indispensable

duties

Apatkale
Both
Reasonable

Unlawful purpose + no alternate resource (burden on alienate)

Beneficial transaction

Benefits test

Prudent transaction

Responsibility of Karta > ordinary person – exclusive property

Religions

Indispensable duty Pious partial not total alienation

Charitable

4.1 Joint Family Property’s alienation can be done in two Ways-

 Express Authorization (With the Consent of all the Coparceners)-

When a Member Other than the Karta of a Coparcenary Property Wills to alienate his/her
share in the Hindu joint family he/she needs consent of all other coparceners to do so.

 Implied Authorization- Implied or Judicial Authorization is when a Karta of the Hindu

joint family wishes to alienate the Joint family property, he doesn’t require the consent of
the other coparceners because he has been given the authority to do so by virtue of law.
Joint Family Property & Its Alienation Page |9

Note- It is to note that only a Karta of the Hindu joint family can alienate through this
method.

4.2 Who All Can Alienate-

The people with the power to alienate coparcenary property are –

1. Karta

2. All coparceners

3. Sole surviving coparcener

4. Father

4.2.1 Power of Alienation of the Karta-

For the Karta to alienate property, he must fulfil one of two requirements which include –

 It was justified for benefit of estate by legal necessity.

 He made fair and bona fide inquiries and acted for the benefit of the estate in good faith.

The three broad conditions under which property can be alienated are –

1. Legal necessity or “Apatkale”

The term "legal necessity" should be interpreted broadly. It is widely accepted that the term legal
necessity should not be construed in terms of what is necessary, but rather what is decent and fair
in the eyes of a Hindu family. It would suffice if it could be demonstrated that the family's needs
were in need and that the property was alienated to meet those needs.

In Devulapalli Kameswara Sastri v. Polavarapu Veeracharlu7 , the Court stated that necessity
should not be construed in the sense of what is vital, rather what is necessary and prudent in the
eyes of the average Hindu family. Legal necessity, thus, does not imply physical compulsion, but

7
Devulapalli Kameswara Sastri v. Polavarapu Veeracharlu (1911) ILR 34 Mad 422
Joint Family Property & Its Alienation P a g e | 10

rather demand on the property that is serious and sufficient in law. The following have been
deemed legal requirements –

• Settlement of govt. revenue along with debts due from family assets.

• Support for coparceners and their families.

• Marriage expenditures for coparceners and their children.

• Shraddha, funeral, and other religious rites for members of the undivided family.

• Litigation costs if necessary.

• Legal fees incurred when the breadwinner or another household member faces a

Significant criminal charge.

• Repayment of indebtedness accrued for the family business.

• Sale of property for the family's advantage.

2. Benefit to estate or “Kutumbarthe”

If the alienation of the family's common property advances the family's financial interests and does
not violate the law, it is justifiable, regardless of whether it has a protective element if the
transaction is advantageous for the family. In such a situation, the court must be persuaded by the
evidence that the arrangement was intended to benefit the family. In a joint family with
coparceners, they both are obligated to make crucial decisions for the welfare of the estate.

In Palaniappa v. Devsikmony8 , the Privy Council stated that the expression "benefit of the estate"
as it appears in rulings justifying an alienation cannot be accurately defined. The term "estate"
implies land ownership. In the context of shared family property, estate refers to shared family
land. Initially, the term "benefit of the estate" protected only cases of a strictly defensive nature,
such as protecting the estate from imminent danger or destruction, but it was eventually expanded
to include alienations that an average, reasonable man would find appropriate under the
circumstances. Consequently, the benefits may include the preservation of the estate from any

8
Palaniappa v. Devsikmony (1911) ILR 34 Mad 535
Joint Family Property & Its Alienation P a g e | 11

harm, the defense against hostile litigation that impacts it, and the protection against damage or
flood degradation.

In the case “Balmukund v. Kamlawati & Ors”9 , the Supreme Court declared that a transaction
need not be defensive in order to be considered for the family's advantage. In lieu of this, the court
must be satisfied with the evidence presented, regardless of whether it was intended to provide an
inherited benefit or not.

In the case of “Hari Singh v. Umrao Singh”10 , the court determined that the sale was advantageous
when non-producing land was sold and producing land was purchased.

3. Indispensable Duties or “Dharmamarthe”

The word "indispensable duties" refers to the execution of moral, pious, or charitable works.
Included are annual shraddhas, the upanayana ceremony, everyone's wedding, and all other
religious festivals. Aside from these ceremonies, donations are permissible for religious purposes,
the property may be alienated.

In the case of “Gangi Reddy v. Tammi Reddi”, the Court determined that the Karta may transfer a
small portion of a religious charity's family property without the consent of all coparceners
provided the allocated property is negligible in contrast to the family's total assets.

9
Balmukund vs. Kamlawati & Ors 2003 (2) SLJ 370 CAT
10
Hari Singh vs. Umrao Singh 1980 AIR 701, 1980 SCR (2) 501
Joint Family Property & Its Alienation P a g e | 12

4.2.2 Coparceners Power of Alienation-

Earlier Coparceners had no rights to Alienate the Joint family property, Our Smritikars or
Mitakshara School of law did not specify about Coparceners Right of Alienation. With time this
Right came into existence as an outcome of judicial Interventions. It can be done under two ways-

1. Involuntary Alienation- Also Known as Alienation of Undivided Interest, while being

primarily recognized for protecting creditors' interests by the privy council in 1873,
coparceners have been granted the power to alienate their undivided interest in coparcenary
property [Deen Dayal vs. Jagdeep (1876)].11 However, the alienation cannot be made if
the coparcener passes away before the case is filed, before the procedures are adjudicated
in the creditor's favor, or before the court attaches the coparcenary property.
2. Voluntary Alienation- After it was proved that a coparcener's undivided interest could be
sold to satisfy a money judgement against him, it was logical to apply the same reasoning
to voluntary alienation. A voluntary alienation happens when a property owner transfers
ownership voluntarily. Apparently, the notion that if a coparcener can be compelled to do
something, he should also be permitted to do it on his own terms was extended to voluntary
alienations.
There are several ways to alienate voluntarily:
 Gift- A coparcener may only give coparcenary property with the approval of all other
coparceners; otherwise, the gift is void.
 Mortgage/Lease- Coparceners have been given the right to alienate their undivided
interest in the coparcenary by means of mortgage or lease provided it doesn’t
adversely affect the rights of other coparceners.
For instance, if A uses his portion of the undivided property as security for a loan
obtained by alienation, his liability is limited to the amount of his portion. This loan
is not the responsibility of the other coparceners.
 Renunciation of interest- A coparcener has the right to renounce his interest in the
coparcenary property, but the renunciation must be made in the favour of a member
of the coparcenary and not in the favour of a third party. The Privy Council determined

11
Hindu joint family & Karta right of alienation - IJIRL, https://ijirl.com/wp-content/uploads/2022/02/HINDU-
JOINT-FAMILY-KARTA-RIGHT-OF-ALIENATION.pdf
Joint Family Property & Its Alienation P a g e | 13

in the case of Alluri Venkatapathi Raju vs. Venkatnarasimha Raju12 that a coparcener's
renunciation of his interest merely extinguishes his interest in the joint estate and has
no other effect other than to decrease the number of people to whom shares will be
allotted if and when the estate is divided.
 Will- Before 1956, a coparcener was not allowed to give away his share through a
will. However, since 1956, coparceners have been able to legally alienate property in
anyone's favour through a will. This alienation will take effect upon the passing of the
coparcener.

4.2.3 Sole Surviving Coparceners Power of Alienation-

When all of the Coparceners die except for one, that Coparcener is considered the sole survivor.
When such Coparcener acquires joint family property, it becomes separate property, provided that
such Coparcener is heirless13.

Based on various judicial decisions, there are now three perspectives on the power of the sole
surviving Coparcener to alienate a Hindu joint family property:

 The sole living coparcener has complete authority to sell, mortgage, or gift the property.
At the moment of the alienation, however, no other family member may have a shared
interest in the family property. Furthermore, if another Coparcener is present in the womb
at the time of such alienation, such coparcener can challenge or ratify the alienation after
reaching the age of majority.
 This estrangement shall not be contested/ challenged by a child born later or an adopted
child. In contrast, if another member was conceived and is in his mother's womb at the time
of alienation, the sole surviving coparcener does not have the power to alienate, and the
member, upon birth, may contest or ratify such alienation upon reaching majority.
 Since the implementation of the Hindu Succession Act in 1956, the sole surviving
coparcener has been prohibited from alienating the widow's share. The sole surviving

12
TP MAIN SCRIBD, https://www.scribd.com/document/386908689/tp-main-docx

13
(Vyas, 2020)
Joint Family Property & Its Alienation P a g e | 14

Coparcener may not dispose of the interest of a female whose interest has been vested in
her, according to Section 6 of the Hindu Succession Act of 1956.

4.2.4 Fathers Right to Alienation-

If the Father is a Karta and out of love and affection, he set aside a small portion of the Joint family
property for his daughter that Alienation is his Right and would be considered Valid.

Although while conduct of this practice a lot of questions were raised in front of court of law, that
the "small portion" is how much of the property, can he only gift moveable property or he can also
gift immovable property to his daughter. Can he do the same in manner of pious obligation for his
other relatives or other Coparceners or not.

With Regards to how much of the joint family property constitutes a small portion it has been held
that it is subjective and can differ case to case basis. In “R Kuppayee v. Raja Gounder” 200414,
1/26 of the property was held valid as small portion although gifting of those portions in no
circumstance should defeat the rights of other Coparceners.

Regarding what type of property can be alienated in favor of daughters it was held that any type
of property can be alienated for gifting her till the time other requirements under law are being
fulfilled.

Regarding the question of whether same can be done for other Coparceners or relatives it was held
in “Gauramma v. Mallappa”15 that this power of Alienation is a special power and can only be
exercised in favour of daughters.

Father usually gives this small portion to her daughter with respect to marriage, before, after or
during. Though this is thought to be an old practice when Daughters was not made Coparcener and
it was father's pious obligation to give something from the family property to daughters, after 2005
Amendment this somehow changed as daughters was anyway made Coparceners.

14
R. Kuppayee v. Raja Gounder, (2004) 1 SCC 295
15
Guramma Bhratar Chanbasappa Deshmukh v. Mallappa Chanbasappa, (1964) 4 SCR 497
Joint Family Property & Its Alienation P a g e | 15

4.3 Coparceners Right to Challenge Alienation-

The alienation can be contested in the case where the father, the Karta, the Coparcener or the lone
surviving coparcener abuse their authority. It can be contested as soon as the person entitled to do
so becomes aware of it and until it is time-barred.

 When alienation is challenged, the burden of proof falls on the alienee to show that it
occurred for a valid cause. When sons contest a father's alienation for paying off his
personal debts, the alienee is responsible for establishing that the loan was incurred by the
father. However, if the sons allege that the loan was tainted (thus acknowledging that their
father did accept the obligation), the burden of proof lies with the sons.
 Coparcener who was in the womb at the time of alienation-A coparcener who is in his
mother's womb at the time of alienation has the ability to disregard such alienation after
his birth. According to Hindu law, a son conceived is in every way equal to a son born.
This also applies to an alienation made by the last remaining co-captive.
 After coparcener's birth- A sole coparcener or Karta, who has no male progeny, may
lawfully alienate the joint family property. Such estrangement cannot be challenged by a
son born later. If a father with sons forms an alienation and another son is born to him
before all boys die, even after the death of all sons existing at the time of alienation, the
later-born son may fight the alienation if the right has not yet expired. The overlap of lives
affords him this right; nevertheless, at the time of his creation, at least one coparcener must
have had a valid right to contest alienation.
 Adopted Son- Adopted son after alienation does not have the right to contest alienation,
even if alienation was invalid at the time it was made.
Joint Family Property & Its Alienation P a g e | 16

4.4. Rights and Remedies of an Alienee-

4.4.1 Rights of Karta-

If the alienation is lawful, the alienee will acquire all the rights of a mortgagee against the
mortgager without any further action being required.

In the states of Maharashtra, Madhya Pradesh, and Madras, where the alienation is set aside only
to the extent of the non-alienating coparcener's share, there is no equity entitling the alienee to a
refund of a proportionate portion of the appraised value in relation to those shares, making the
alienee's situation extremely unclear if the alienation is deemed invalid.

According to the Privy Council's decision in “Narayan Pd v. Sarmam Singh”16, an alienee has no
equity against the purchase price in jurisdictions where an alienation can be nullified in its whole.
The Calcutta High Court ruled in “Hasmat v. Sundar”17, that if the father's alienation was voided,
the resulting debt would become the responsibility of the sons; as a result, the sons would be unable
to rescind the sale without first repaying the original purchase price.

16
Narayan Pd v. Sarmam Singh 1917 P.C. 41
17
Hasmat v. Sundar (1885) ILR 11 Cal 396
Joint Family Property & Its Alienation P a g e | 17

4.4.2 Rights of Coparceners-

 Right of joint possession- If one coparcener sells their undivided interest in their property
to another, the buyer don’t obtain the right to co-possession with any other coparcener.
Forcing a partition of this property is the only recourse he has. If the buyer is an outsider
who is not currently living on the property, then Mitakshara School holds that he has no
right to share in the property's possession with the other coparceners and that his only
option is to have the property partitioned. If such a person has achieved possession, the
non-alienating coparceners are allowed to co-possession with him.

 Right to mesne profits- The members in possession of the coparcener's interest are
obligated to award the buyer mesne (previous earnings) from the time of the sale until the
suit for partition is filed.

 Right to share on partition- The share to which a purchaser is entitled upon partition is
the share to which the alienee was entitled on the date of alienation, not on the date the
alienee attempts to convert his interest into possession.

 Right to sue for partition after coparcener’s death- Aliens retain their right to partition
even after the death of the coparcener. He can bring a lawsuit against the coparcener's heirs
for the property he was entitled to.

 Right to sue for specific performance- If the coparcener who is selling his interest passes
away before the sale is finalized, the buyer might sue for performance of the sale
agreement.
Joint Family Property & Its Alienation P a g e | 18

5. Findings & Suggestions-

Karta of the joint family has been given implied authority by virtue of law to alienate the joint
family property without other coparceners’ consent, though there are specified conditions only
under which he can do so but as the property is in joint possession law can be revised to think
about adding certain amendments to it about making the “consent of other coparceners” a valid
essential for Karta to alienate the Joint Family Property. Though it can depend on case-to-case
basis on the facts and circumstances. This is an important question to think about, a recent case
was also raised in the similar matter in SC, and where the question raised was whether or not is it
mandatory for Karta to take signature of the other coparceners when he decides to alienate the joint
family property?

Facts of the case was the Karta of a Joint Hindu Family consisting of his wife, and his son, and
himself had alienated a property out of Legal Necessity without his son's signature.

Karnataka High Court held that:

“The agreement to sell is unenforceable as the suit property belongs to the joint Hindu family
consisting of three persons, K. Veluswamy, his wife V. Manimegala and his son V. Manjunath and,
therefore, could not have been executed without the signatures of V. Manjunath”.18

Though in the similar matter given the established legal precedent, the Supreme Court determined
that V. Manjunath, the son of Karta - K. Veluswamy, did not need to sign the purchase agreement.
Being the Karta, K. Veluswamy had the right to sign the agreement to sell as well as alienate the
suit property. The absence of V. Manjunath's signature is unimportant and of no consequence. In
our opinion, the concept of Karta and giving him sole right to take decision regarding a joint family
property is a very old concept which can be again looked into due to the change in times, as the
main essential of a coparcenary property is unity of possession and community of interest, other
coparceners should not be deprived of their right to give their consent in important matters related
to JFP.

18
Explained| can karta alienate joint Hindu family property without ... scconline,
https://www.scconline.com/blog/post/2021/12/14/explained-can-karta-alienate-joint-hindu-family-property-without-
coparceners-signature/
Joint Family Property & Its Alienation P a g e | 19

6. Conclusion-

Therefore, it is possible to reach the conclusion that alienation is an essential component of

coparcenary property and so is the comprehension of the conditions surrounding the time and
people who can divide the property, as well as the conditions under which they can do so. This
study aims to cover these integral features of alienation, which also form a crucial component of
the “Hindu Succession Act of 1956” and serve as a basis for a knowledge of Hindu law.
Joint Family Property & Its Alienation P a g e | 20

6. Bibliography

Books Referred

1. Gunther-Dietz Sontheimer, The Joint Hindu Family: Its Evolution as A Legal Institution,
Munshiram Manoharlal Publishers Pvt Ltd, (1977)

Articles Referred

1. Pushkar Sinha, Hindu Joint Family and Karta Right of Alienation, Indian Journal of Integrated
Research in Law

2. Prachi Bhardwaj, Can Karta Alienate Joint Hindu Family Property Without Coparcener's
Signature, SCC Online Blog

3. Pooja Shrivatsava, Legal Necessity as a Ground for Alienation of Joint Family Property,
Academia

4. Dr. Travina Vyas, Joint Family Property: Its Investment, Alienation and Partition, Ijrar

5. Saimy Eliza Abraham, Short Note on Hindu Joint Family Under Mitakshara and Dayabhaga,
Studocu

Websites Referred

1. SCC Online, https://www.scconline.com/web-edition

2. HeinOnline, https://home.heinonline.org/content/

3. Manupatra, https://www.manupatrafast.com/