व्यवहारमयूख (नीलकण्ठ भट्ट - पश्चिमी भारत की हिन्दू न्याय-संहिता एवं व्यवहार कोष)

S. IV. 10. 2-3 ] STRĪDHANA 177
M. p. 91 l. 46-p. 92 l.14 ]
*Yājñavalkya ( II. 143 ) is easily explained ( or harmonized )
What was given ( to a woman ) by her father, mother, husband or
brother, what was presented to her before the ( nuptial ) fire, wealth given
to her on supersession and the like are enumerated as strīdhana
( woman's peculium ).¹
And Visnu ( Dh. S. 17. 18 ) mentions more ( varieties than six ) ∙
What was given ( to a woman ) by her father, mother, son and brother,
what was presented to her before the ( nuptial ) fire, wealth given on her
husband marrying ( another woman ), what was given by her relatives
( or cognates like the maternal uncle ), s'ulka and anvādheyaka² ( these
are the kinds of strīdhana )
Kātyāyana defines adhyagni ( given before the nuptial fire ) and the
other kinds ( of strīdhana )³
What is given to women at the time of marriage before ( the
the nuptial ) fire that is declared by the wise to be adhyagni strīdhana.
That again which a woman obtains when she is being taken ( in a pro-
cession ) from her father's house ( to the bridegroom's ) is declared to be
strīdhana of the adhyāvāhanika kind⁴ Whatever is given to ( a

---

negatived. On the point of adverse possession there is a conflict of decisions. In Kanhai
Ram v. Musammat Amri 32 All. 189 it was held following 5 I. A p 1 that what is acquired
by a woman by adverse possession becomes her stridhana, vide also Krishnai v Shripati 30
Bom 383, Subramanian v Arunachellam 28 Mad. 1 at p. 7. But in Lajwanti v. Safa
Chand 51 I. A 171 (= 5 Lahore 192 ) it was said ' if possessing as widow she possesses
adversely to anyone as to certain parcels, she does not acquire the parcels as strīdhana, but
she makes them good to her husband's estate' This was followed in Anant v Mahadeo 31
Bom. L R 628 But in 46 All. 760 and Suraj Balli Singh v. Tilakhdhari 7 Patna 163 and
in Sant Baksh Singh v Bhagwan I L R. 6 Lucknow p. 365 at p 873 the P. C case of
Lajwanti v Safa Chand was explained and it was held that if a widow holds property
adversely it becomes her strīdhana As regards property acquired by a widow from the
accumulations of the income of her husband's property vide Isri Dutt v Hansbutti 10
Cal. 325 ( P. C. ), Saudamini v Administrator-General of Bengal 20 Cal 433 ( P. C. ); 41
Cal. 870.

1. In Brij Indar v. Ranee Janki L R. 5 I A 1 this verse of Yāj is quoted (at p. 14)
   and it is said "And the words ' and the like' or ' such like ' would show that the author
   did not intend to limit his definition to the particular kinds of property therein enumerated."
   Ādhivedanika is wealth given to a wife as a solatium when she is superseded and the husband
   marries another woman. It is defined by Yāj. II 148 ( quoted in the text below ) Yāj I.
   78 mentions the circumstances under which alone the supersession of a wife was allowed.
   In Bhugwandeen v. Mynabaee 11 Moore's Indian Appeals at p 512 it is said that the Vivāda-
   cintāmaṇi and Mayūkha confine stridhana within the definitions of Manu and Kātyāyana
   and that they exclude the property inherited and the other acquisitions which are compre-
   hended in the last clause of the para of the Mitākṣarā
2. S'ulka and anvādheyaka are explained in the verses of Kātyāyana quoted below.
   3 Vide notes to Kātyāyana verse 894 for the origin and development of strīdhana in
   Vedic times and the times of the sūtras
   4 The V. R. ( p 528 ) says that when the married girl is taken back from the bride-
   groom's house to her father's, what is given by the father-in-law and others is also
   adhyāvāhanika.

• P. 158 ( text ).
  V. M. 23