Abstract
The evolution of women’s property rights in India signifies a remarkable journey from social exclusion to legal recognition and judicial empowerment. Historically bound by patriarchal Hindu laws, women were denied equal inheritance, restricted to limited stridhan ownership, and excluded from ancestral property. The enactment of the Hindu Succession Act, 1956 initiated codified inheritance reform but retained gender bias by excluding daughters from coparcenary rights. The Hindu Succession (Amendment) Act, 2005 marked a historic legislative correction, granting daughters equal rights and liabilities as sons in joint family property. This research paper traces the legislative and judicial trajectory of women’s property rights, critically analysing key cases such as Prakash v. Phulavati (2015), Danamma v. Amar (2018), and Vineeta Sharma v. Rakesh Sharma (2020). Through doctrinal and analytical approaches, it evaluates the judicial interpretation that restored gender parity in inheritance. The study concludes that despite constitutional and legal progress, social barriers, lack of awareness, and procedural challenges continue to impede the full realisation of women’s proprietary equality.
Introduction
Property ownership, within the socio-legal framework of India, transcends mere economic entitlement; it signifies autonomy, dignity, and social empowerment.1 Historically, however, women in India were systematically denied equal proprietary rights, a consequence of entrenched patriarchal norms that positioned them as dependents within familial hierarchies rather than as autonomous holders of property. Under ancient Hindu law, particularly the Mitakshara school, succession operated within a strictly patrilineal framework where property devolved through the male line. Women were largely excluded from coparcenary rights and could inherit property only under restricted conditions, often as limited owners rather than full proprietors. In contrast, the Dayabhaga school, though comparatively progressive, granted women a semblance of inheritance rights, yet these remained constrained by custom and religious sanction.
The trajectory of women’s proprietary rights began to shift with the Hindu Women’s Right to Property Act, 1937, a colonial-era reform that recognised women’s claim to inheritance for the first time but confined their ownership to a life interest rather than absolute rights2. Following independence, the Constitution of India enshrined the ideals of equality and non-discrimination under Articles 14 and 15, thereby laying a normative foundation for gender justice in property relations. However, despite the codification of Hindu law under the Hindu Succession Act, 1956, the retention of a male-exclusive coparcenary continued to institutionalise gender disparity in joint family property.
A transformative shift occurred with the Hindu Succession (Amendment) Act, 2005, which accorded daughters the same coparcenary rights as sons, ensuring legal recognition of women as equal heirs.3 This reform was constitutionally reinforced through judicial interpretation, most notably in Vineeta Sharma v. Rakesh Sharma (2020), where the Supreme Court affirmed the retrospective application of the amendment and upheld the principle of substantive equality in inheritance.4
This paper therefore seeks to trace and analyse the evolution of women’s right to property in India — from the patriarchal foundations of traditional Hindu law to the transformative constitutional and judicial developments that have sought to secure women’s equal status as property holders.
Historical Context: Gender Inequality in Traditional Hindu Law
The origins of gender inequality in Hindu property law can be traced to the patriarchal foundations of ancient Hindu jurisprudence, which viewed lineage and inheritance primarily through the prism of male succession. Under the Mitakshara school, property was conceptualised as a joint family asset, wherein sons acquired rights by birth (known as janmasvatva). This doctrine ensured that property perpetually circulated within the male line, thereby excluding daughters from coparcenary rights5. Their entitlement was restricted to maintenance, marriage expenses, or dowry — none of which conferred ownership or control over ancestral assets. The doctrine of survivorship further cemented this exclusion, as property upon the death of a male member devolved to surviving male coparceners, effectively disinheriting female heirs.
The Dayabhaga school, which governed Bengal and parts of Eastern India, deviated slightly by recognising inheritance only upon the death of the father rather than by birth. Yet, even within this framework, women’s inheritance was conditional and temporary — typically extinguished upon remarriage or death. The limited recognition of stridhan, meaning property gifted to a woman at the time of marriage or through affection, provided some semblance of financial autonomy. However, stridhan was often symbolic and lacked parity with male inheritance, reflecting societal perceptions of women as dependents rather than proprietors.
During the colonial period, the British administration largely adopted a policy of non- interference in personal laws, preserving the gendered inequities inherent in Hindu inheritance traditions. The Hindu Law of Inheritance Act, 19296, for the first time, recognised certain female heirs such as the son’s daughter, daughter’s daughter, and sister as heirs to a deceased’s estate. Nonetheless, this legislation maintained the overarching precedence of male succession. Similarly, the Hindu Women’s Right to Property Act, 1937 introduced a modest reform by granting widows a limited estate in their husband’s property. However, this right was life-estate in nature and did not extend to full ownership, thereby failing to dismantle patriarchal property relations.
By the mid-twentieth century, women’s proprietary position under Hindu law remained distinctly subordinate. Their economic participation and property rights were mediated through male guardianship, reflecting a broader social structure rooted in dependence and inequality. This systemic marginalisation necessitated comprehensive statutory reform to harmonise Hindu inheritance law with the constitutional principles of equality and non-discrimination enshrined in post-independence India7.
The Hindu Succession Act, 1956: Reform and Retention of Patriarchy
The enactment of the Hindu Succession Act, 1956, marked a significant moment in the history of property rights in India. It was part of the larger Hindu Code Bills drafted after independence to modernise personal laws, with an aim to dismantle centuries-old patriarchal structures embedded in Hindu joint family systems. The Act extended succession rights to Hindu women in respect of separate property, thereby abolishing long-standing discriminatory customs that had previously denied them independent ownership and inheritance. In particular, the inclusion of women as Class I heirs in the schedule to the Act was a progressive step, as it ensured that widows, mothers, and daughters could claim property on par with male heirs. This provision, in theory, provided women with a legal status as inheritors rather than mere dependents8.
Despite these reforms, the Act simultaneously preserved the patriarchal ethos of Hindu succession by retaining the Mitakshara coparcenary system under Section 6. In this framework, coparcenary rights in ancestral property were limited to male members who acquired a right by birth, while daughters could only inherit in a derivative sense—as heirs of a deceased coparcener. In effect, this statutory design excluded women from joint ownership, thereby creating a disjunction between the promise of equality and its practical realisation. Critics argue that while the Act introduced “formal equality” in succession, it did not dismantle the structural foundation of gender inequality entrenched in the joint family system. The doctrine of survivorship under Mitakshara law further compounded this exclusion, as property devolved within the male line, leaving daughters on the margins of coparcenary ownership.
This compromise is reflective of the socio-political climate of the 1950s, where the reformist zeal of the post-independence state was tempered by conservative pressures to preserve family traditions. Legal scholars have argued that the Act symbolised the state’s cautious approach— granting women some inheritance rights while deferring the complete dismantling of patriarchal privilege. Nevertheless, the Hindu Succession Act, 1956, laid the foundation for more transformative legislative and judicial interventions. It initiated a discourse on gender justice in property rights, setting the stage for subsequent reforms such as the 2005 Amendment, which eventually equalised coparcenary rights9.
The Hindu Succession (Amendment) Act, 2005: A Legislative Milestone
The Hindu Succession (Amendment) Act, 2005, constituted a watershed moment in Indian succession law, as it directly addressed the gender-based exclusions entrenched in the 1956 legislation. By substituting Section 6, the Amendment declared that daughters are coparceners by birth, placing them on an equal footing with sons in respect of rights and liabilities in ancestral property. This reform marked the abolition of the doctrine that confined coparcenary membership exclusively to males, thereby eroding the central patriarchal tenet of the Mitakshara joint family system. The Amendment not only signalled legislative intent to align personal law with constitutional guarantees of equality but also represented a symbolic recognition of women as stakeholders in familial wealth and property.
Among its salient features, the Amendment repealed Section 23, which had barred female heirs from seeking partition in a dwelling house until male heirs chose to divide it. This provision, long criticised as discriminatory, reinforced women’s dependence on male family members for realising their property rights. Similarly, the repeal of Section 24, which had disqualified certain remarried widows from inheritance, reflected a progressive shift away from archaic moral judgments about women’s personal choices. These deletions, along with the redefinition of Section 6, sought to harmonise property law with the principles of non-discrimination embodied in Articles 14 and 15 of the Indian Constitution.
However, the Amendment generated significant judicial debate regarding its temporal scope. The critical question was whether daughters would be entitled to coparcenary rights retrospectively from birth, or only prospectively from the date of the amendment. Conflicting interpretations by various High Courts and the Supreme Court deepened the uncertainty. In Prakash v. Phulavati (2015), the Supreme Court held that the amendment applied only prospectively, excluding daughters whose fathers had died before 2005. This position was later contrasted by the Court in Danamma v. Amar (2018), where daughters were recognised as coparceners even though the father had died prior to the amendment. The judicial inconsistency culminated in the landmark ruling of Vineeta Sharma v. Rakesh Sharma (2020), where a three- judge bench of the Supreme Court clarified that the 2005 Amendment conferred coparcenary rights to daughters by birth, irrespective of whether the father was alive on the date of the amendment.
Thus, while the 2005 Amendment represented a legislative milestone in dismantling gendered exclusions in Hindu succession, its effectiveness was shaped and consolidated through judicial interpretation. The combination of statutory reform and judicial pronouncements collectively advanced the constitutional vision of substantive equality for Hindu women in property rights.
Judicial Developments and Interpretations
The evolution of women’s coparcenary rights in Hindu law is deeply shaped by judicial interpretations that have sought to harmonise statutory text with the constitutional vision of gender equality. The Hindu Succession (Amendment) Act, 2005 marked a transformative step towards recognising women as equal coparceners in ancestral property. Yet, its judicial construction has undergone a series of interpretative challenges that reveal the complex interplay between legislative intent, temporal application, and constitutional principles. The three pivotal decisions — Prakash v. Phulavati (2015), Danamma @ Suman Surpur v. Amar (2018), and Vineeta Sharma v. Rakesh Sharma (2020) — together trace the trajectory from restrictive interpretation to the affirmation of women’s inherent coparcenary rights.
Prakash v. Phulavati (2015): Prospective Application of the 2005 Amendment
In Prakash v. Phulavati, the Supreme Court was tasked with determining the temporal scope of the 2005 Amendment to Section 6 of the Hindu Succession Act, 1956. The Court held that the Amendment was prospective, meaning that it would apply only if both the father (coparcener) and daughter were alive on the commencement date, i.e., 9 September 2005. This interpretation effectively restricted the Amendment’s application, excluding daughters whose fathers had passed away before that date from claiming coparcenary rights.
The Court reasoned that the conferment of coparcenary rights was not a mere recognition of pre-existing entitlements but the creation of a new statutory right, which could not operate retrospectively. By adopting a strict constructionist approach, the judgment prioritised certainty in property relations over the broader remedial purpose of gender justice. However, critics argued that this interpretation diluted the transformative intent of the 2005 reform, which was to eliminate gender-based discrimination in ancestral property and place daughters on an equal footing with sons. The ruling in Phulavati thus generated considerable debate, as it effectively perpetuated patriarchal inheritance structures under the guise of legal formalism.10
Danamma @ Suman Surpur v. Amar (2018): A Conflicting Precedent
In Danamma @ Suman Surpur v. Amar, the Supreme Court appeared to depart from the ratio of Phulavati. Despite the father’s death occurring in 2001 — prior to the 2005 Amendment — the Court granted coparcenary rights to the daughters. This decision suggested that the right of a daughter as a coparcener is by birth, and hence not contingent upon the survival of the father. Such reasoning reflected a more purposive interpretation, aligning with the Amendment’s objective of gender equality and legislative intent.
However, the judgment’s departure from Phulavati without expressly overruling it resulted in considerable judicial inconsistency. Lower courts were left uncertain as to which precedent to follow. The coexistence of conflicting judgments not only complicated the application of the law but also risked unequal treatment of similarly situated daughters, depending on the interpretation adopted by different benches.11 This inconsistency called for authoritative clarification by a larger bench, particularly on whether the Amendment conferred a new right or merely recognised a pre-existing one that was constitutionally implicit.
Vineeta Sharma v. Rakesh Sharma (2020): Affirmation of Daughters’ Birthright
The interpretative conflict was conclusively addressed in Vineeta Sharma v. Rakesh Sharma, where a three-judge bench of the Supreme Court reconciled the divergent precedents and firmly established that a daughter’s right to coparcenary property arises by birth, not by the survival of her father. The Court clarified that the 2005 Amendment did not create a new right but simply recognised a pre-existing entitlement grounded in constitutional guarantees of equality. The judgment, therefore, gave the Amendment retrospective effect, applying it to all daughters irrespective of whether the father was alive on 9 September 2005.
Justice Arun Mishra, delivering the judgment, observed that gender equality in inheritance was a constitutional mandate, and any interpretation that subordinated it to technicalities would undermine the transformative spirit of the law. The Court also emphasised that the Amendment must be interpreted in light of Articles 14 and 15 of the Constitution, which prohibit gender discrimination and ensure equal protection before the law.12 By affirming that daughters possess coparcenary rights by birth, the Court not only restored the legislative purpose but also aligned statutory inheritance law with constitutional morality.
The decision in Vineeta Sharma represents a watershed moment in the judicial journey of women’s property rights. It harmonises the Hindu Succession Act with egalitarian principles, effectively dismantling the remnants of patriarchal lineage embedded in Mitakshara law. Furthermore, by granting the Amendment retrospective applicability, the Court reinforced that gender cannot determine succession, thereby upholding the spirit of substantive equality.13
Collectively, these judicial pronouncements trace a gradual yet decisive movement from formalistic interpretation towards substantive gender justice. While Phulavati reflected judicial conservatism, Danamma signalled transitional flexibility, and Vineeta Sharma culminated in the constitutional realisation of equality in coparcenary rights. The 2020 judgment thus stands as a landmark in harmonising statutory reform, constitutional vision, and the jurisprudence of equality in Indian family law.
Socio-Legal Implications
Despite the enactment of progressive legislation and the evolution of favourable judicial precedents, the realisation of women’s property rights in India remains deeply constrained by entrenched socio-cultural barriers. Legal empowerment does not necessarily translate into practical empowerment, as societal norms often continue to dictate the distribution and control of family assets. In numerous rural and semi-urban contexts, daughters are either subtly persuaded or overtly pressured to relinquish their legal entitlements in favour of male relatives, particularly brothers. Such relinquishment is frequently framed as an act of familial duty or moral obligation, reflecting the pervasive influence of patriarchal ideologies that equate male ownership with family stability and continuity14.
Furthermore, structural obstacles such as inadequate awareness, procedural complexities, and poor access to legal resources significantly impede the enforcement of inheritance rights. Many women lack documentary evidence to substantiate their claims, a challenge compounded by the informal nature of property transactions in rural India. Social stigma associated with litigation within family structures further deters women from pursuing their entitlements through formal legal channels. As a result, the gap between the normative promise of equality and its lived experience remains substantial.
Empirical research consistently underscores the transformative potential of property ownership for women. Secure property rights not only provide economic stability but also enhance women’s bargaining power within both household and community settings. Ownership of immovable assets has been linked to greater participation in decision-making processes, improved access to credit and financial services, and increased capacity for entrepreneurial initiatives. It also contributes to broader goals of poverty reduction and intergenerational equity by enabling women to transfer wealth and security to future generations.
Thus, the question of women’s inheritance is not merely a matter of statutory interpretation but a crucial determinant of social justice and economic development. Effective implementation of inheritance equality demands not only judicial vigilance but also robust policy interventions aimed at awareness generation, legal literacy, and structural reform. Bridging the divide between legal rights and social realities is essential to ensure that women’s entitlement to property becomes both a lived and enforceable reality, thereby advancing gender justice within the broader framework of constitutional equality.
Challenges in the Realisation of Women’s Right to Property in India
Despite the landmark legislative reforms introduced through the Hindu Succession (Amendment) Act, 2005, and progressive judicial pronouncements, the realisation of women’s right to property in India remains an arduous task. Although statutory provisions confer equal inheritance rights to daughters, multiple socio-cultural, procedural, and institutional impediments continue to undermine their effective implementation. The following section elaborates upon the multifaceted challenges that impede the full realisation of these rights in practice.
Social Resistance and Cultural Stigma
A major barrier to women’s inheritance rights stems from deep-rooted patriarchal norms that govern family relations and property distribution. In traditional Indian society, property ownership has historically been linked to lineage preservation and male authority. Consequently, when daughters attempt to claim their lawful share in ancestral property, they are often perceived as disrupting familial harmony or acting against customary expectations.
Social stigma plays a crucial role in discouraging daughters from asserting property rights against their brothers or paternal kin. In many communities, women who claim inheritance are labelled as greedy or disrespectful towards their family. Fear of social ostracism and emotional guilt compels many women to relinquish their property rights voluntarily. Moreover, marriage practices reinforce the notion that a daughter, having received dowry or “stridhan,” should not seek a share in ancestral property. This cultural conditioning sustains gender bias and deters women from exercising their legal entitlements, despite the statutory equality conferred by the 2005 Amendment.
The persistence of patriarchal ideologies underscores that legal reform alone cannot dismantle centuries of social conditioning. The transformation of social attitudes is therefore essential for ensuring substantive equality. Public awareness campaigns, community engagement programmes, and sensitisation initiatives are required to challenge the entrenched stereotypes that portray women as passive beneficiaries rather than rightful owners.
Procedural Barriers and Costly Litigation
The procedural complexities of the Indian legal system pose another significant challenge. Litigation relating to property disputes is often prolonged, expensive, and emotionally draining. For many women, particularly those from lower socio-economic backgrounds, the cost of
hiring legal representation, attending court hearings, and obtaining necessary documentation becomes prohibitively high.
In addition, property records in India frequently suffer from inaccuracies, lack of digitisation, and fraudulent transfers, making it difficult for women to establish ownership claims. Bureaucratic red tape and corruption within land and revenue departments further aggravate these challenges. Many women, especially widows and daughters living away from their natal homes, struggle to access legal documents or evidence required to substantiate their rights.
As a result, the combination of economic constraints, procedural delays, and institutional inefficiencies effectively denies women the justice guaranteed by law. Streamlining procedures, promoting alternative dispute resolution (ADR) mechanisms, and expanding access to affordable legal aid are necessary measures to address these procedural obstacles.
Lack of Awareness and Legal Literacy
Another critical impediment is the lack of awareness among women regarding their inheritance rights. Despite the Hindu Succession (Amendment) Act, 2005, granting daughters equal coparcenary rights, a substantial proportion of women remain uninformed about these provisions. Studies indicate that legal illiteracy is particularly prevalent in rural and semi-urban regions, where patriarchal norms dominate and formal education levels are lower.
Without adequate awareness, women cannot assert their entitlements or challenge discriminatory practices. Even when they are aware, misconceptions regarding legal procedures and fear of family disputes often prevent them from seeking judicial recourse. Thus, the gap between law and lived experience persists due to inadequate dissemination of legal knowledge.
The state and civil society must therefore prioritise initiatives that promote legal literacy. Campaigns conducted through panchayats, self-help groups, and women’s collectives can play a transformative role in educating women about their rights and available legal remedies. Incorporating gender sensitisation into educational curricula can also foster long-term attitudinal change.
Women’s access to justice remains deeply unequal, particularly in rural areas where legal infrastructure is underdeveloped. Many women face logistical and institutional barriers such as distance from courts, lack of female legal professionals, and absence of dedicated legal aid centres. Even when legal aid is available, the quality of representation often remains inadequate due to limited resources and low levels of gender sensitivity among officials.
Moreover, the intersection of gender with class, caste, and geographic location compounds these inequalities. Marginalised women are often unaware of procedural timelines, documentation requirements, or modes of appeal. The absence of gender-sensitive judicial processes and the intimidating atmosphere of courtrooms discourage women from pursuing claims.
Addressing these challenges requires the establishment of rural legal aid clinics, mobile legal counselling units, and gender-sensitised judicial training. Expanding the reach of para-legal volunteers and leveraging technology to facilitate online legal services can enhance accessibility and efficiency.
Absence of a Uniform Civil Code and Fragmented Legal Framework
The continued existence of personal laws based on religion perpetuates inequality in property rights across different communities. While Hindu women have benefitted from statutory reforms such as the 2005 Amendment, women belonging to other religious groups, particularly Muslims and Christians, continue to face limitations under their respective personal laws. This creates a fragmented legal landscape where gender equality is contingent upon religious identity rather than constitutional guarantees.
The absence of a Uniform Civil Code (UCC) thus sustains systemic disparities in women’s property rights. Although Article 44 of the Indian Constitution envisions a UCC to ensure uniformity and equality, its implementation remains politically and socially contentious. A harmonised legal framework could potentially eliminate inconsistencies and uphold the constitutional promise of gender justice across all communities.
Conclusion
In conclusion, while the legislative framework in India now recognises gender equality in inheritance, its practical realisation remains hindered by entrenched social norms, procedural hurdles, lack of awareness, and institutional inequities. Achieving substantive equality requires a holistic approach that combines legal reform with societal transformation. Strengthening legal literacy, enhancing access to justice, reforming procedural mechanisms, and addressing cultural resistance are crucial steps toward ensuring that women’s right to property becomes a lived reality rather than a mere legal abstraction.
Only through sustained efforts involving the state, civil society, and community institutions can India bridge the gap between de jure equality and de facto empowerment.
The journey of women’s right to property in India epitomises the gradual dismantling of entrenched patriarchal inheritance structures through constitutional, legislative, and judicial reform. From the exclusionary doctrines of ancient Hindu law to the enactment of the Hindu Succession Act, 1956, and its progressive amendment in 2005, the legal system has sought to rectify centuries of gender-based discrimination. The landmark judgment in Vineeta Sharma v. Rakesh Sharma reaffirmed the constitutional mandate of equality by recognising daughters as coparceners by birth, placing them on an equal footing with sons in matters of inheritance. This decision not only clarified interpretative inconsistencies arising from earlier rulings but also underscored the judiciary’s commitment to advancing gender justice within the framework of personal law15.
However, despite these normative achievements, the lived reality of women across India reveals a significant gap between law and practice. Patriarchal mindsets, customary resistance, and procedural barriers continue to hinder the effective realisation of property rights. Many women, especially in rural and semi-urban regions, are discouraged from asserting their lawful claims due to familial pressure, lack of awareness, or the prohibitive costs of litigation. Consequently, legislative progress often remains symbolic unless complemented by systemic reforms and attitudinal change.
Ensuring women’s ownership and control over property is therefore not merely an aspect of personal empowerment, but an essential condition for achieving the broader constitutional ideals of equality, dignity, and social justice enshrined under Articles 14, 15, and 21 of the Constitution. True gender justice necessitates a holistic approach that integrates legal awareness, administrative efficiency, and gender-sensitive adjudication. Strengthening legal aid mechanisms, simplifying inheritance procedures, and fostering societal sensitisation can bridge the divide between formal equality and substantive justice. Ultimately, the recognition of women’s property rights must evolve beyond legislative declarations to tangible social economic empowerment, reaffirming their rightful place as equal stakeholders in familial and societal wealth.
Footnotes
- Agarwal, Bina. A Field of One’s Own: Gender and Land Rights in South Asia. Cambridge University Press, 1994. https://doi.org/10.1017/CBO9780511522000 ↩︎
- Hindu Women’s Right to Property Act, 1937 (Act No. XVIII of 1937). https://indiankanoon.org/doc/1119978/ ↩︎
- Hindu Succession (Amendment) Act, 2005. https://indiankanoon.org/doc/1993727/ ↩︎
- Vineeta Sharma v. Rakesh Sharma (2020) 9 SCC. https://indiankanoon.org/doc/141008609/ ↩︎
- Derrett, J. Duncan M., Introduction to Modern Hindu Law, Oxford University Press, 1963.
Available at: https://archive.org/details/in.ernet.dli.2015.276187 ↩︎ - Hindu Law of Inheritance Act, 1929 (Act No. II of 1929).
https://indiankanoon.org/doc/1883290/ ↩︎ - Hindu Women’s Right to Property Act, 1937 (Act No. XVIII of 1937).
https://indiankanoon.org/doc/1441949/ ↩︎ - Agnes, Flavia, “Hindu Women’s Right to Property—Recent Trends” (1992) 29 Economic and
Political Weekly. ↩︎ - Menski, Werner, Hindu Law: Beyond Tradition and Modernity (Oxford University Press,
2003). ↩︎ - Prakash v. Phulavati, (2016) 2 SCC 36. Available at:
https://indiankanoon.org/doc/34907031/ ↩︎ - Danamma @ Suman Surpur v. Amar, (2018) 3 SCC 343. Available at:
https://indiankanoon.org/doc/101953269/ ↩︎ - Vineeta Sharma v. Rakesh Sharma, (2020) 9 SCC 1. Available at:
https://indiankanoon.org/doc/192347245/ ↩︎ - Article 14 and Article 15, Constitution of India. Available at: https://www.india.gov.in/my
government/constitution-india ↩︎ - Agarwal, Bina. A Field of One’s Own: Gender and Land Rights in South Asia, Cambridge University Press, 1994. ↩︎
- aphc.gov.in ↩︎
