Stridhana and Woman's Property — Hindu Law (Family Law I) Notes

Stridhana and Woman’s Property

In Pratibha Rani v. Suraj Kumar (1985), the Supreme Court clarified once and for all: Stridhan is a woman’s absolute property. When in-laws retain a woman’s jewellery and gifts after she leaves the matrimonial home, they are guilty of criminal breach of trust under Section 405 IPC — it is theft from the wife, not the family’s property.

What is Stridhana?

Stridhana (literally “woman’s property”) is property that belongs absolutely to a woman, over which she has full powers of ownership including the power to sell, mortgage, gift, and bequeath by will.

Sources of Stridhana (traditional classification by Manu):

1. Gifts at the time of marriage — from parents, in-laws, relatives, husband, brother, strangers.
2. Gifts before the nuptial fire (adhyagni) — at the time of the marriage ceremony.
3. Gifts at the bridal procession (adhyavahanika).
4. Gifts given in token of love (pritidatta) — from husband or in-laws.
5. Gifts from father (pitrida) — gifts made by father during the woman’s lifetime.
6. Gifts from brother (bhratridatta).
7. Property acquired by her own effort — by inheritance, partition, purchase, compromise, or adverse possession.

Section 14, HSA 1956 — Full ownership: Any property possessed by a female Hindu — whether Stridhan or otherwise — is held by her as full owner (not limited owner). This abolished the old “widow’s estate.”

Section 14(1), HSA 1956: “Any property possessed by a female Hindu, whether acquired before or after the commencement of this Act, shall be held by her as full owner thereof and not as a limited owner.”

In Simple Terms: Stridhan is hers absolutely — she can do with it whatever she wishes. No one can claim it during her lifetime. After death, it passes by succession under Sections 15-16.

Case Laws

• Pratibha Rani v. Suraj Kumar (1985) — Stridhan is absolute property of the wife; retention by in-laws is criminal breach of trust.
• V. Tulasamma v. Sesha Reddi (1977) — Section 14(1) has a wide scope; it includes all property in possession, irrespective of how it was acquired.
• Bhagat Ram v. Teja Singh (2002) — A widow’s property under S.14(1) is absolute; the old law of “widow’s estate” is completely abrogated.

Back to Top

📄 Full notes + Question Bank (₹199) — every topic in depth, model answers to all past KSLU questions, in one printable PDF. Get the bundle · 10 Solved Problems · All Hindu Law topics