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

260 VYAVAHĀRAMAYUKHA [ S. XVIII 1-5
M. p.144 l. 23-p.145 l. 28
Now begins (the section on) heinous offences
Nārada (p. 202 v 1) says about the nature of sāhasa
Whatever act is performed by force by those who are puffed up with
(the pride of) strength is called sāhasa (a heinous offence), sahas here
means strength¹
Bṛhaspati (p. 359 v 1) says
Homicide theft assault on another mans wife and the two kinds of
pāruṣya (viz. abuse and assault)—these are the four kinds of sāhasa

• Ubhayam means both abuse and assault Nārada (p 203 vv 4-6)
  says
  Destroying fruits roots, water and the like and implements of
  husbandry throwing away or reviling them and trampling upon them—
  this is declared to be sāhasa of the first degree destroying &c. clothes,
  cattle food or drink or household utensils is declared to be middling
  sāhasa taking human life by poison weapons or other means, assault on
  the wife of another and whatever else endangers human life is called
  sāhasa of the highest degree
  Yājñavalkya (II. 273) says
  The king shall cause to be impaled on stakes those who make others
  captive those who (forcibly) carry away horses and elephants and who
  kill others by force
  Bṛhaspati (p. 363 v 30) says
  Those who are openly murderers and those who are secret assassins
  shall be put to death by the king by various modes of execution after find
  ing them out and after confiscating their property
  The same author (Bṛhaspati p. 363 v 31) says
  Where several persons in anger beat a single individual (and kill him)
  that man is declared to be the murderer (and suffers the punishment for
  murder) who strikes (the victim) on a vital part (i e. who gives the fatal
  blow).
  ¶ Kātyāyana says
  One who commences a sāhasa, or aids it, or who gives instructions as to the
  way (in which it may be committed) who gives asylum or furnishes
  weapons or food to evil-doers who advises fighting who incites to the
  destruction of the person (killed) who connives (at the commission of
  an offence) who speaks ill (of the person killed &c) who approves (of
  the offender's act) who though able (to prevent an offence) does not
  forbid it—all these are (practically) perpetrators of the deed (The king)
  should prescribe for them suitable punishments according to the capacity

1. Steya must be distinguished from sāhasa. In the former there is no use of force
   or threat of using it; in sāhasa there is use of force or threat of the use of it.
   P 239 (text) ¶ P 240 (text)