3. Property or strIdhana? The British rule These two different sytems, and more often the DB, were the reference which English Judges used to establish that strIdhana and property are two different concepts; one meaning a wife's exclusive right of use and alienation over her property, which is termed stridhan, and the other meaning her use with certain restrictions and only when still alive, namely a limited estate.

There has been continuing controversy on the reason why the High Court of Bombay followed the principle that the inherited property was not stridhan. In the Bombay Presidency, the judgements of the Privy Council and the various High Courts decided that the female heirs were divided into two categories:

1. females who were born in the family of the deceased owner such as daughter, sister, brother's daughter,
2. females who belonged to the family of the owner by marriage (his wife, his mother, his brother's wife and the wives of his other relatives).

The case of Pranjivandas Tulsidas vs. Devakuvarbai²⁸ can be taken as an example of the above. Sir C. J. Sausse, speaking for the Court, in that case observed:

"On the whole, I think, the spirit and practice of Hindu law, as recognized in western India, will be best construed by treating the widow as having uncontrolled power over the movable estate, but as having nothing more than that a life-use in the immovable estate..."

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