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 The word ‘’Streedhan’ has been derived from
the Sanskrit words ‘Stri’ meaning a woman
and the word ‘dhan’ means property.
Therefore on combining these two words, we
get ‘property of woman’ her ‘Stridhan’.
 These two words imply that property over which
a woman has an absolute ownership. The
‘Stridhan’ must be without any consideration in
return thereof. Stridhan is a concept of Hinduism
only.
 Gifts and bequeaths from relations.
 Gifts and bequeaths from strangers during
maidenhood.
 Property obtained on partition.
 Property given in place of maintenance.
 Property acquired by inheritance.
 Property acquired by mechanical arts.
 Property acquired by adverse possession.
 Property purchased with the savings her
income.
 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,
Benaras 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.
 Purchased Property 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 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 stidhan, while the
Privy Council held such property as 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 it.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 (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
 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.
 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
 Pratibha Rani vs. Suraj Kumar 1985 (2) SCC
370
 The court held that A woman’s right to her
Stridhan is protected under law. S. 14 of the
Hindu Succession Act, 1956 R/w S. 27 of the
Hindu Marriage Act, 1955 make a female Hindu
an absolute owner of such property.
 “a Hindu married woman is the absolute owner
of her Streedhan property and can deal with it in
any manner she likes and, even if it is placed in
the custody of her husband or her in-laws they
would be deemed to be trustees and bound to
return the same if and when demanded by her”.
 Ashok Laxm an Kale vs Ujwala Ashok Kale AIR 2007
(NOC) 1093
 The bride has got an absolute, exclusive dominion over
all her Streedhan, received during the marriage. This
includes both movable and immovable property, while
she has the power to sell, alienate or give it away as she
pleases both during her lifetime and thereafter. Her
husband and in-law’s family members have no rights
over a woman’s Streedhan. We need to understand that
the marriage expenses and dowry are not Streedhan.
 Vinod Kumar Sethi v. State of Punjab AIR 1982 P&
H 372 held that dowry and traditional presents made to a
wife at the time of the marriage constitute her stridhan.
 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
 Chinnappa Govinda v. Valliammal AIR1969
MAD 187 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.
Stridhan

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Stridhan

  • 1.
  • 2.  The word ‘’Streedhan’ has been derived from the Sanskrit words ‘Stri’ meaning a woman and the word ‘dhan’ means property. Therefore on combining these two words, we get ‘property of woman’ her ‘Stridhan’.  These two words imply that property over which a woman has an absolute ownership. The ‘Stridhan’ must be without any consideration in return thereof. Stridhan is a concept of Hinduism only.
  • 3.  Gifts and bequeaths from relations.  Gifts and bequeaths from strangers during maidenhood.  Property obtained on partition.  Property given in place of maintenance.  Property acquired by inheritance.  Property acquired by mechanical arts.  Property acquired by adverse possession.  Property purchased with the savings her income.
  • 4.  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, Benaras and Madras schools.
  • 5.  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.  Purchased Property 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
  • 6.  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 stidhan, while the Privy Council held such property as woman’s estate.
  • 7.  (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 it.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 (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
  • 8.  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.  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
  • 9.  Pratibha Rani vs. Suraj Kumar 1985 (2) SCC 370  The court held that A woman’s right to her Stridhan is protected under law. S. 14 of the Hindu Succession Act, 1956 R/w S. 27 of the Hindu Marriage Act, 1955 make a female Hindu an absolute owner of such property.  “a Hindu married woman is the absolute owner of her Streedhan property and can deal with it in any manner she likes and, even if it is placed in the custody of her husband or her in-laws they would be deemed to be trustees and bound to return the same if and when demanded by her”.
  • 10.  Ashok Laxm an Kale vs Ujwala Ashok Kale AIR 2007 (NOC) 1093  The bride has got an absolute, exclusive dominion over all her Streedhan, received during the marriage. This includes both movable and immovable property, while she has the power to sell, alienate or give it away as she pleases both during her lifetime and thereafter. Her husband and in-law’s family members have no rights over a woman’s Streedhan. We need to understand that the marriage expenses and dowry are not Streedhan.  Vinod Kumar Sethi v. State of Punjab AIR 1982 P& H 372 held that dowry and traditional presents made to a wife at the time of the marriage constitute her stridhan.  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
  • 11.  Chinnappa Govinda v. Valliammal AIR1969 MAD 187 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.