The Millennium University Journal

Vol. 2, No. 1; 2017

ISSN 2225-2533
Published by The Millennium University

Dowry Deaths in Bangladesh: A Study on Obligation under

International Covenant on Civil and Political Rights

Dr. Abdullah-Al- Monzur Hussain

Assistant Professor and Head
Department of Law
Canadian University of Bangladesh, Dhaka, Bangladesh
E-mail: idhrle_bd@yahoo.com

Abstract
The dowry system has been included in Bangladeshi Marriage system from Hindu marriage culture. In the rural
areas, impact of this system is highly visible where it is treated as an essential component of every marriage contact.
Dowry system has become a deep –rooted social custom and for this, many women are murdered, or they commit
suicide. Interestingly, these incidents are caused those are vowed to protect them legally and socially. In
Bangladesh, different kinds of laws have been introduced to minimize the social menace. Bangladesh is the member
of International Covenant on Civil and Political Rights where right to life and prohibition on arbitrary deprivation of
right to life is ensured. But non payments of dowry deaths are on the rise despite legal intervention. This paper
attempts to explain that lack of enforcement of anti-dowry laws, and also non-fulfillment of human rights obligation
as mentioned in International Covenant on Civil and Political Rights by Bangladesh, are the main causes of dowry
related maltreatments and even deaths of the young married women.

Keywords: Dowry, ICCPR, Human Rights, Police, Obligation.

1. Introduction
After reviewing the women empowerment system, the position of woman in Bangladeshi society has not
changed remarkably, which is very important for the balanced development of the country. Because of the gender
equality, opportunity to enter into various opportunities, resources, rule of law and good governance are very
challenging. Most of the woman does not have any access to the freedom of choice for self-development because of
the existing customs of Bangladeshi society. Because of the dowry, the status of women in is degrading in various
areas especially in rural areas.
Existing dowry system has made a daughter family burden and a son an asset as he collects dowry. Dowry
is considered as a social malady as it makes the lives of newly wed girls or even homemakers extremely miserable
and the news of killing of housewives has become regular in the newspaper. However, many social activists and
woman rights organizations are working to overcome the situation but it is not changing. Though most of the dowry
harassment related cases are reported lately but a staggering number had not. Despite all attempts to prevent it, an
epidemic appears to be in the making (M.A. Khan, 2012). These situations are happening because of the faulty
enforcement of dowry prohibition laws and cultural attitude towards women in Bangladesh.
Failing to prevent the dowry menace in Bangladesh, as a party to the International Covenant on Civil and
Political Rights (ICCPR), violates the obligation of ensuring ‘right to life’ as expressed in Article 6(1) and protected
by Article 2.This paper discusses the phenomenon of dowry menace generally and explains the meaning and
emergence of dowry in Bangladesh. In addition, it examines the laws enacted by Bangladesh in response to growing
incidence of dowry deaths. This article also explores that the practice of dowry death not only violates the existing
laws of Bangladesh but also violates international human rights law as embodied in the ICCPR. It finally examines
the violation of obligations under Article 2 of the ICCPR with respect to the right to life by Bangladesh and suggests
some measures that Bangladesh should adopt to meet its obligations under the ICCPR.

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2. Definition and Significance of Dowry

Dowry is the durable goods, cash, and real and movable property that the bride’s family (Rani Jethamalani & P.K.
Dey, 1995) gives to the bridegroom, his parents, or his relatives as a condition of the marriage. According to the
Section 2 of the Dowry Prohibition Act, 1980, dowry is any property or valuable security given or agreed to be
given either directly or indirectly by one party to a marriage by another party at any time before or after the marriage
as a consideration of marriage. Dowry concept has come from Hindu law. Unlike Muslim law, in Hindu law,
marriage is a ceremony instead of civil contract. Under the Hindu law, women do not inherit the property from their
parents. For this reason, at the time of marriage, women are given some properties in kind or cash by their parents
within their financial capacity, By the passage of time, the custom of dowry has been developed from this practice of
Hindu law.
In recent years, dowry has become an essential part of nearly every marriage and is obtained through
applying constant coercion or pressure on the newly wedded women (ASK: Rights and Realities, 1997). There are
many factors such as traditional culture, an unequal power relation between men and women, the growing
unemployment problem among young men and commercialization of marriage contribute to the persistence of
dowry in Bangladesh. The patriarchal society in Bangladesh acknowledges men’s superiority over women. To
establish this superiority, men preferably receive family supports and attention in favor of developing their
independent and productive careers. Consequently, the bargaining power and rating of dowry depend on the level of
educational and occupational status of the groom (A. Nangia, 1997). Economic dependence and powerlessness of
women have created an image of ‘unproductive burden’ for the family. So women is staying in the parental home at
the marriageable age is not welcome.
‘Superfluous ego’ is developed for the special attention from both sides and it is a feeling of power among
grooms’ families that help dowry transform into a demand. Besides, decline in moral values and greed for the
improved life make marriage a business transaction. In recent times, marriage began to lose its sanctity (A Nangia,
1997) and is used as a means of making money, in which more value is given to property and cash money than that
of the bride herself. As one of the potential means to change fate, even a poor uneducated man may exploit a bride’s
family. In numerous instances, the groom’s dowry demand does not match with the annual income and wealth of the
bride’s father. On some occasions, a ticket to the Middle East to find a job is demanded as dowry (S.R. Khan, 2001).
Dowry system is highly patronized by the richer section of the country, which offers luxury items ranging from
ornaments to land properties through arranging a grand formal gathering. It serves to display their wealth status in
the society and to motive young people to nurture dowry. By this way economical and socio-cultural factors are
encouraging the continuation of dowry in Bangladesh.

3. Dowry Deaths and the Failure of Existing Legal Responses

Bangladesh’s practice of arranged marriages, which involves the giving and receiving of dowry, is at the root of
dowry deaths. “Dowry deaths” is the collective name of the various kinds of fatalities (Barbara Crossette, 1989). In
Bangladesh the most popular way to murder a young bride is to strangulate and hang her from the ceiling so that it
seems to suicidal death. Murder by burning is also grimly expedient. The sari of combustible cloth worn by the bride
ensures that she will burn quickly and easily. Since these murders are committed behind closed doors, the murderers
can later claim that the young bride died as a result of an accident or suicide. There are generally no witnesses to
refute such claims, nor does any evidence remain (Elisabeth Bumiller, 1990).
Although there are no accurate statistics on the number of dowry deaths per year, the number of registered
cases has risen steadily. In January 7, 2012, “ODHIKAR” one of the leading non-governmental human rights
organization of Bangladesh published annual human rights report of 2011. According to the report of ODHIKAR,
from January, 2001 to December, 2011, 2303 women were killed due to dowry (Human Rights Report, 2011). Only
from January to December, 2011, 305 women lost their life because of dowry. Despite these higher figures,
evidences indicate that a number of additional murders and attempted killings of young brides are not reported
simply because the bride’s families prefer to avoid publicizing what they consider to be a shameful incident.
Moreover, the husband and his relatives disguise many such deaths as suicides or accidents. Consequently, many
fear that the actual occurrence of dowry deaths far exceeds the number reported to the police. This occurrence is
continuing due to the lack of enforcing the existing anti dowry laws and the attitudes and discrimination towards
women.
After 1970s the practice of dowry became so rampant that official legal recognition became inevitable.
Consequently, in 1980 the Dowry Prohibition Act was enacted in Bangladesh and subsequently modified a number
of times (S. Huda, 2006). The Dowry Prohibition (amendment) Ordinance, 1982 enables an individual to file a
dowry suit directly to the court (Section 4). The 1984 amendment broadens the scope of dowry by providing that:
dowry ‘at the time of marriage or any time is illegal. The amendment of 1986 extended the penalty for claiming
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dowry in any form before or after marriage up to a maximum of 5 years imprisonment, and made dowry a non-
cognizable and non-bailable offence. In response to the growing incidence of dowry –related deaths, the government
of Bangladesh enacted more stringent law as the name, Women and Children (Repression Prevention) Act, 2000.
Under this Act of Section 26, Special Tribunals have now been set up in every district to try all cruel and criminal
acts, including dowry death cases (Section 26). This Special Tribunal is empowered to impose death penalty for
murder because of dowry. However, the studies show that the above mentioned statutes have not been successful in
significantly reducing levels of dowry –related deaths in Bangladesh.
The continuing problem of dowry deaths is the non-enforcement of criminal laws by police and
prosecutors. However, police seldom enforce arrests in proportion to the total numbers of incidents and very
reluctant to recognize dowry as a crime. In numerous instances, police refused to arrest the criminals and even
denied registering the case brought by women, believing that victims provoked the violent incidents. Likewise, the
manipulation of the investigating process by the police has been one of the serious barriers to getting a favorable
remedy in dowry cases. There is ample evidence in Bangladesh that dowry deaths are frequently labeled as
accidental or suicidal. On some occasions, no action is taken, even after years, ‘until evidence disappears’ (F.D.
Chowdhury, 2010). The failure of the police to investigate and to take proper action helps many offenders to go
legally unchallenged, while the state places arrest at the discretion of the police. Without any legal compulsion to
arrest, police often improperly occupied with their self-interest in arresting abusers, especially those who are
influential in terms of economic and political power. Such an approach ignores not only the ‘vulnerable position’ of
a female victim in an unequal abusive relationship but also presents serious flaws in the criminal laws of the
country.
The judiciary also contributes to the small number of dowry-related prosecutions. Dowry complaints are
given such low priority that it can often take up to one year before the court even agrees to grant a hearing.
Moreover, courts often suppress certain crucial evidence, such as suicide notes and dying declarations, on technical
grounds.
Cultural attitudes toward women provide another impediment to effective enforcement of laws prohibiting
dowry and criminalize dowry murder (Melissa Spatz, 1991). From childhood, especially in rural areas, a woman is
taught that she will marry the man her family chooses. Once married, a woman must make a place for herself in her
new family. Furthermore, she must serve husband selflessly, bear everything without complaint. The society
reinforces this theme, instructing women to remain devoted to their husbands no matter what their husbands do to
them. The prestige of both families depends on the women remaining in the marriage. Over and above, social mores
dictate that a woman must never speak out against her husband, and a broken marriage is viewed as a disgrace both
to the woman’s family and to her own honor. Consequently, Bangladeshi women rarely accuse their husbands or in-
laws of violence. Instead, they suffer harmful abuse in silence. As a result of these cultural attitudes, parents and
neighbors rarely offer to help the new bride. Even when a bride has the courage to seek help, her parents almost
always refuse to allow her to return home out of fear of public humiliation. Thus, the bride, who has nowhere to turn
for help, is placed at great risk of a dowry-related death.

4. Dowry Deaths and International Human Rights Law

Not only does the practice of dowry death violate the existing domestic laws of Bangladesh, but also it violates
international human rights laws, specifically the ICCPR. Section 4.1 of this part briefly describes ICCPR. Section
4.2 states that dowry deaths are arbitrary deprivation of right to life under the ICCPR. Finally section 4.3 explains
Bangladesh’s obligations under the ICCPR with respect to the right to life and argues that Bangladesh is in violation
of its treaty obligations.

4.1 Dowry and the ICCPR

The ICCPR is one of three international human rights treaties collectively known as the International Bill of Rights
(Richard B. Lilich, 1991). All three treaties are part of a United Nation’s effort to protect human rights. The purpose
of the ICCPR is to protect the Civil and Political rights of individuals. To this end, Article 28 of the ICCPR
establishes a Human Rights Committee consisting of 18 members to administer the enforcement mechanisms
provided for in the ICCPR. The ICCPR provides for enforcement of its provisions through two means administered
by the Human Rights Committee: interstate complaints and self-reporting by member states. In addition, a
companion treaty to the ICCPR, the Optional Protocol, provides for an individual petition procedure. Unfortunately,
victims of dowry crimes and their families are unable to avail themselves of any of these methods for enforcing
rights under the ICCPR. Only states may utilize the first two means (indicates inter-state communication and
reporting system). The individual petition procedure, which allows individuals to lodge petitions claiming violations
of the ICCPR against member states, is unavailable because Bangladesh is not a party to the Optional Protocol. But
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this lack of an enforcement mechanism for victims of dowry crimes does not mean that dowry deaths do not violate
the right to life under the ICCPR.

5. Dowry Deaths and Arbitrary Deprivation of Life

According to Article 6(1) of the ICCPR, “every human being has the inherent right to life.” Right to life is the most
fundamental of all human rights because it is the essential right from which all other rights derive; if an individual is
deprived of his/her right to life, all other human rights will be meaningless (Yorman Dinstein, 1981). Article 4(2) of
the ICCPR prohibits derogation from Article 6(1) even in time of public emergency threatening the life of the
nation. While Article 6(1) does not specify the scope of protection that must be accorded the right to life, it does
mandate that “no one shall be arbitrarily deprived of his life”. One of the leading scholars has stated that the
emphasis must be on both ‘deprive’ and ‘arbitrarily’. “Deprivation of life” is viewed as being synonymous with
homicide. Thus, the right to life is, in effect, the right to be safeguarded against arbitrary killing.
As to the word “arbitrary,” the drafters of the ICCPR extensively debated its use in Article 6 (B.G.
Ramcharan, 1985). Critics argued that the term did not express a generally recognized idea and was inherently
ambiguous (Marc J. Bosssuyt, 1987). In fact, at least nine separate views on the meaning of ‘arbitrary’ were
propounded during the drafting. Representatives to the drafting committee recalled that in drafting the Universal
Declaration of Human Rights, the Human Rights Commission had similar difficulty in defining the word ‘arbitrary’,
and were unable to reach agreement. Members of that drafting committee propounded definitions of arbitrary that
included ‘illegally’, ‘unjustly’, and both. One delegation said that it could be interpreted to include accidental
deaths, while others disagreed; arguing that an act of conscious will or intention was required. A number of
representatives maintained that the clause meant that no person could be deprived of his life ‘except in accordance
with law. Others proposed that ‘arbitrarily’ should mean ‘fixed or done capriciously or at pleasure; without adequate
determining principle; depending on the will alone; tyrannical; despotic; without cause upon law; not governed by
any fixed rule or standard. Some believed the term was synonymous with the phrase ‘without due process of law’.
Finally, some construed the term to imply ‘such guarantees as the right to fair trial and protection against false
arrest.’
Analyzing the dowry death phenomenon in light of the fore-going interpretations as to the meaning of
‘arbitrary’ in Article 6(1), and in accordance with the view that the right to life should receive the greatest possible
protection, it is clear that dowry deaths constitute illegal or arbitrary killings; the murder of brides in dowry disputes
is not permitted under Bangladeshi law, and is in fact criminalized. But are dowry deaths an arbitrary deprivation of
life within the meaning of Article 6(1)? There has been some question as to whether, if a state fails to prevent the
killing of one individual by another, it violates Article 6(1).
However, one scholar points out, this argument ignores the fact that it is the right to life, not life itself,
which must be protected by law under Article 6(1). As he explains, the right to life is a legal concept that prohibits
deprivation of life except under conditions prescribed by law. Thus, it is reasonable to infer that the state must
criminalize the deliberate taking of life by any individual.
The question of whether state action is required to violate the right to life under the ICCPR was debated in
the course of the drafting of Article 6(1).
While the view was expressed that the article should concern itself only with the protection of the
individual from unwarranted actions by the State … the majority thought that States should be called upon to protect
human life against unwarranted actions by public authorities as well as by private persons …
The interpretation of Article 6(1) has especially important ramifications for Bangladeshi women. Because
dowry killings are perpetrated by private individuals, the husbands and/or in-laws of Bangladeshi brides, they fit within
the type of action prohibited under Article 6(1). Consequently, the women of Bangladesh have the express right under
Article 6(1) of the ICCPR to be protected by the state against dowry-related murders. Because of their arbitrary,
unwarranted, and illegal nature, dowry deaths do constitute arbitrary deprivations of life within the meaning of Article
6(1).

6. Bangladesh’s Obligations under the ICCPR

Having determined that dowry deaths constitute arbitrary deprivations of life under Article 6(1), it is necessary to
determine the nature and extent of the obligations of Bangladesh to protect the right to life of the women in
Bangladesh.
While there is no general rule of international law that requires treaties to have effect in domestic law,
(Oscar Schachter, 1981) Article 6(1) requires that the right to life be protected by law. The drafters of the ICCPR
intended the provision to obligate each state party to have a law or laws within its internal legal system protecting
the right to life. The meaning of ‘law’ was strictly interpreted because of the supreme importance of the inviolability
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of life, requiring that the right to life be protected by higher forms of law, such as statutes or constitutional
provisions.
Clearly, Bangladesh has complied with this facet of its obligation, insofar as it has enacted statutes
prohibiting dowries and criminalizing dowry deaths. However, the Article 6(1) requirement that the right to life be
protected by law is not the extent of a state’s obligations under the Covenant. Under Article 2(1) of the ICCPR,
states parties to the Covenant must also undertake ‘to respect and to ensure to all individuals within their territories
and subject to their jurisdiction the rights recognized in the Covenant.
A state can fulfill the obligation “to respect” simply by not violating the rights set forth in the Covenant
(Thomas Buergenthal, 1981). Bangladesh has, therefore, fulfilled its obligation to respect the right to life in
connection with dowry deaths because the government does not perpetrate these crimes. However, Article 2(1) also
requires states “to ensure” the rights expressed in the ICCPR, including the right to life. This obligation imposes an
affirmative duty on the state to take any measures necessary to enable individuals to enjoy and exercise their right to
life under the Covenant, including taking all possible measures to prevent violations of this right by others.
Furthermore, such measures must be ‘adequate’ and ‘effective’. At the very least, a state must exercise due
diligence to prevent international deprivations of life by individuals, as well as to apprehend and prosecute
murderers as a deterrent to future takings of life. Thus, Article 2(1) requires Bangladesh to take positive steps to
ensure the right to life, including preventing the murder of wives by husbands and in-laws in dowry disputes.
Bangladesh has complied with this obligation only to the extent that it has taken some positive measures, including
enacting statutory law prohibiting dowries and providing for punishment of perpetrators of dowry crimes. However,
Bangladesh has not taken all possible measures, as is required, nor have the steps taken by Bangladesh proved
adequate or effective. The number of victims of dowry deaths continues to increase each year (ODHIKAR, Human
Rights Report, 2011).
In support of the requirement that the measures taken by a state must be adequate and effective, Professor
Oscar Schachter notes that the basic commitment of states can be characterized as an ‘obligation of result.’ In other
words, the emphasis is not on the process, but on the result. The ICCPR does not require specific measures to give
effect to the rights in the Covenant. Rather, Article 2(2) specifies the way in which states parties are to carry out
their obligations to respect and ensure the rights recognized in the ICCPR. “Where not already provided for by
existing legislative or other measures, each State Party to the present Covenant undertakes to take necessary steps…
to adopt such legislative or other measures as may be necessary to give effect to the rights recognized in the present
Covenant.” This phrasing leaves open the precise character of the measures, which can include incorporation of the
ICCPR into domestic law or other legislative, executive, or administrative orders.
The ICCPR leaves open for determination in specific cases whether or not legislative or other measures
will be necessary at all. According to the language of Article 2(2), if legislative or other measures are already
provided for in existing law, then it is not necessary to adopt any new legislative or other measures. However, while
the obligation to implement new legislative and or other measures is conditional on their being necessary, it is
nonetheless an obligation, and one that a state violates if it provides such legislative or other steps and they prove
ineffective, as with Bangladesh and dowry deaths.
Paragraph 3 of Article 2 of the ICCPR specifies additional obligations, including a requirement that persons
whose rights have been violated are ensured an effective remedy. It also requires that an individual’s right to such a
remedy be determined by a competent authority “provided for by the legal system of the State” and that any
remedies granted be enforced by the competent authorities. These provisions impose independent obligations on the
states parties. Thus, it is insufficient for a party to maintain that its respects and ensures rights; it must also discharge
its obligation to use the means specified in Article 2 through its domestic legal system ‘to give effect’ to the rights or
to repair violations.
What is meant by ‘to give effect’ is not clearly specified. However, a right is typically given effect by (i)
avoiding or preventing violations of the right, and (ii) in the event that the right is violated, providing remedies to
the victim. To satisfy the first of these obligations, a state may choose to enact legislation. However, the Human
Rights Committee has noted that legislative enactments are often not per se sufficient (H.A. Kabaalioglu, 1985).
Professor Schachter, in apparent agreement, states that the citation of statutory and constitutional law may
satisfy the need for legislation, but is never a sufficient answer to the question of whether ‘other measures’ are
required to give effect to the right to life or any other right granted under the Covenant. Moreover, Schacter explains
the circumstances under which a state has failed to give effect to a right guaranteed by the Covenant: “if it is
impossible or difficult for aggrieved individuals to obtain an objective determination of their rights under the
Covenant… or if state organs, including the courts, diverge in practice from the proclaimed rules, it is clear that the
obligations of Article 2 are not satisfied.

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It is true that Bangladesh has attempted, through legislative enactments, to prevent dowry deaths and
punish perpetrators of dowry crimes. However, at present these measures have proved insufficient. The numbers of
dowry death victims continue to rise, and slipshod investigations and lax enforcement of anti dowry laws leave
victims and their families with little or no remedies. Thus, because the steps taken by Bangladesh have proved
inadequate and ineffective in preventing dowry deaths and providing remedies when they do occur, the inescapable
conclusion is that Bangladesh is in violations of its Article 2 obligations with respect to the Article 6(1) right to life.

7. Concluding Remark
Because of the violation of Article 2 obligations under the ICCPR, Bangladesh remains unsuccessful to protect the
right of the Bangladesh women. If we have to search for the true remedies for the few surviving victims of dowry
deaths and the families, as the police, prosecutors, and courts do not effectively enforce either the laws prohibiting
dowry or those punishing dowry crimes. Because of the current lack of adequate and effective measures in
Bangladesh, Article 2 of the ICCPR mandates that Bangladesh take additional steps to support and reinforce the
existing law protecting the right to life.
Bangladesh is yet to take any measures but it should be pursued immediately, including educational and
informational activities to inform Bangladeshi society that dowry deaths are not acceptable and will not be tolerated.
At all levels- local, regional and national- dissemination of information should be enhanced in the context of both
governmental and non-governmental activities in/out-school education. Human rights education, particularly as it
relates to dowry deaths and other domestic violence, should be established as a life-long system for all individuals
from childhood.
Additionally, the attitude of the society of Bangladesh towards women should be changed and it must
address the societal factors that lead to domestic violence and murder. Bangladesh also has to confront the issue of
biasness in the courts and criminal justice system, educate it police, judicial officers, including providing and
enforcing penalties for tampering with evidence, succumbing to bribes in exchange for failing to investigate
suspicious and unnatural deaths of women and delaying prosecution.
Steps should be taken to provide employment opportunity to female and to develop an institution to give
realization of the right to life, such as state-operated shelters for harassed brides. It is also necessary to develop a
national group interested in aiding the victims of attempted dowry murderers. It is important to promote legal aid
programs as well. Furthermore, Bangladeshi women should be given more opportunity to become economically
independent so that when they will face a life-threatening marriage, they have an alternative to returning to their
home, committing suicide or being murdered.
Above all, the Ministry of Home Affairs must observe the reported cases of dowry deaths and track the
number of such cases that are registered for prosecution. . To ensure the accuracy of such statistics, the police should
include all deaths of Bangladeshi women resulting from dowry-related cruelty as defined in the Women and
Children (Repression Prevention) Act, 2000. At present, the data which are available is highly inaccurate and many
dowry related deaths are remained without counting. Only with the accurate information, it will be possible to take
proper measurement to comply with its obligation under the ICCPR to protect the right to life.
Many other measurements are necessary to take if the above measurements are proved to be wrong or
ineffective. Certainly, if the obligation to protect the right to life is taken seriously, it will require the Bangladeshi
government and its citizen to examine. On a deeper level, there are many diverse barriers to the enjoyment by
Bangladeshi women of such basic rights as the right to life.
Over and above, it is highly unlikely that above mentioned changes will take place only in Bangladesh.
Changing the attitudes of Bangladeshi society will be difficult, specially when the members of the government will
accept the views that devalue women and condone the dowry death phenomenon. In this place the international law
is important. Although ‘international human rights law … must rely heavily on voluntary compliance by states,’ it
also relies on ‘such moral and other influence as other nations are prepared to exert’ (Richard B. Bilder, 1984).
Depending on the nature of the breach, this pressure can consist of military force, suspension or termination of
reciprocal obligations, a case before the International Court of Justice, economic sanctions, or political sanctions
(John Carey, 1970).
The international community has recognized cultural practices like dowry as a violation of human rights
against women. To implement the international standards set under international law should create pressure on the
countries, which are not properly following the guidelines. The Human Rights Committee and other concern
international parties to the use ICCPR of the means at their disposal to put pressure to control the violation of
Human Rights causing for dowry problem or, practices and proper use of enacting laws of Bangladesh. If the laws
are properly enforced then, it is expected that the dowry deaths for money and property may be stopped.

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