The Law of Manusmriti: An Antifeminist and Anti-Human Manuscript

I. Introduction

The society we live in has a lot of noble values to cherish, concomitantly it has a myriad of social evils like gender bias, racism and caste oppression that need to be eradicated. One of the sources of such evils in the Indian legal context is the Manusmriti (or) Manudharma colloquially called Sanadha Dharma. This manuscript being the oldest law guiding India owes much to the significance of the Legal History of India. The principles in the Manu-Dharma-Shastra owe to a lot of social structures in India including the caste system. The law of Manu itself forms the basis of a lot of birth-based inequality in humans in economic, social aspects especially gender-biased. In this research paper. The law attributes to a lot of practices endorsed by Hindu religious groups and their respective Gods and incorpora-ted in itself the principles of Hindu religious groups. The major two issues with this ancient piece of law are that it segregated people based on caste and their gender identity. This ancient law(Manu-smriti) in India primarily attributes to the patriarchal structure of society and discrimination against women. As a consequence of it, many other laws which came to force at a later point of time had also imbibed in itself the shades of Manuspriti and the discrimination it upholds and this will be understood by the readers of this research work. To lay it out more specific, the aspects of a women’s employment, liberty, property rights, marital obligations and political rights given in Manusmriti will be critically evaluated through this research work. This paper would reflect upon how we as a society gradually came out of this ancient law and saved ourselves from its grave consequences. Thus, the evolution of gender equality through policymaking, governance and especially the law-making concerning the impact of Manusmriti can be understood. By and large, this research would be a criticism of the ancient law in India, Manusmriti from the perspective of gender justice. The researcher has would use the doctrinal research method for conducting this research work. Through this research, the readers would know how such a piece of the law came to force, its origin and the reasons of the ideological base. The researcher would wish to critically analyse the direct contextual script of Manusmriti's gender bias and how it has been

reflected in our social practices.

II. Origin and principles of manus-mriti

Manusmriti or the Law of Manu traces its origin back to the 200 CE (Common Era). It is believed in Hinduism, this piece of law originated from the creator of every existence, Brahma and he passed it on to the first human being on the planet Manu.² This is why it is known as ‘the Law of Manu’ or ‘Manav Dharma Shastra’. Several historians opine that it was written by Manu himself in Sanksrit as a reflection of his thoughts forming a well-organized discourse on important elements of life which includes laws, rights, duties, the conduct of life and other aspects of living. During the creation of Manusmriti, the people of that civilization were living ignorant of the very basic understanding of laws so much so that they were even unaware of the irreplaceable impact of the law on a civilization’s population and its binding nature. In such a situation, the creation of Manu as the first law book in that period helped it garner a lot of praise for its so-called progressive nature. Concomitantly, it faced huge criticism for some of its societal ideas which were more conservative in nature.³ The significance of Manusmriti in the Indian Legal History can be gauged in terms of the fact that it ruled the Ancient Indian Jurisprudence for around 1500 years and all the cases under civil and criminal law were adjudicated using the mother book Manusmriti as the standard reference(sole legislation). Although Manusmriti is formally said to have come to force in 200 CE, the ideas entrenched in the laws of Manu had been accustomed to the Vedic people long ago before it was codified properly and reached its final form in 200 CE by Manu, who is traditionally considered to be the first son of Brahma and the progenitor of the Human race.⁴ People gave much importance to the Manusmriti because people in ancient India believed that the order and welfare of the world was the manifestation of God’s will and wish for the public. There are four life goals to be pursued by every individual according to the Hindu culture which includes dharma(being socially responsible), Artha(generation and distribution of wealth), kama(involving in pleasure), moksha(detachment from material things) and the knowledge about them or the discourse on these goals are called as dharma-shastra, Artha-shastra, kaama-shasthra and moksha-shastra respectively.⁵ In such regard, there were 18 Dharmashastras in total out of which Manusmriti is the most popular and widely followed one. Its wide acceptance owes to the fact that it begins with the origin of the world and the varna system(caste system). Manusmriti is structurally divided into 12 chapters with each of them explaining a different aspect of life such as cosmogony(origin), samskaras(sacraments or sacrifices), upanayanas(initiating religious life) etc.. All of these had one common element which is the idea of caste.⁶ According to the believers of Manusmriti, it contained the basis of an ideal society and the way of human life to arrive at an orderly and divine centred society. The book is a conglomerate of different laws for the governance of human life with respect to his social class and the power of enforcing and executing the law was properly delegated to the rulers and guardians of the society. The Manusmriti is a perfect backscattering of the principles, ideas, customs and practices followed in the society at the time it was created. The principles of Manusmriti possessed a lot of sinister values that had an adverse impact on the Indian masses for ages. Concurrently, one can never deny that the values present in it were the result of people’s ideas in that point of time. There are various principles and preachings in Mansusmriti which is seen very much contrary to the contemporary ideas and therefore the scripture does not align with modern society. One of such principles were the birth of the varna system or the caste-based classification of humans. On the basis of Manusmriti, the population was widely divided into four categories based on their birth identity namely the Brahmins, Kshatriyas, Vaishyas and Shudras.

The picture below denotes the hierarchy of the varna system which arose out of the idea imbibed in Manusmriti. Other earlier dharma-shasthras provided only the value for conducting the lives of Brahmins whereas Manusmriti provided it equal for both Brahmins and Kshatriyas. There are totally 2685 verses in Mansumriti out of which nearly 1000 verses talk about Brahmins and another 1000 about rulers, governance and policymaking leaving out around 8 for vaishyas and only 2 for Shudhras.⁷ This expresses the caste principle of Manusmriti and the extent to which the whole scripture polarized towards the upper castes.

This clearly gives us one message that the core principle of Manusmriti was not towards the society’s welfare but was inclined towards Brahmins and their relation with warriors and kings i.e the Kshathiryas.⁸ In relation to this varna system, Manusmriti introduces a very disruptive concept called blood and occupational purity in 130 and 50 verses respectively. Infact, the most meticulously written principle in the entire law book of Manu is that this blood and occupational purity. The entire structure of the manuscript is architecture in such a manner that the book begins with sages(rishis) asking Manu about the code of life for these four castes and his reply to that question is entirely the structure of the Book. Thus implicitly, it means that the primary goal or scope of this code is to establish the rights and duties of individuals on the basis of these four castes and the inference of it can be that the entire script depicts sacred caste specific laws.⁹ In verse 87 of chapter 1 of the law of Manu, he says, “But in order to protect this universe, the most resplendent one, assigned separate (duties and) occupations to those who sprang from his mouth, arms, thighs, and feet.”¹⁰ This means that Manu believes that inorder to protect the entire Universe, he delegated separate occupations to all the four castes and this according to him was occupational security. And by mouth, arms, thighs and feet, he means the hierarchy of the amount of respect, value and quality of the work assigned to four castes respectively. This was occupational security according to Manu that people of each caste must indulge only in the work assigned to them and never try to do the occupation delegated to some other caste. In verses 88, 89, 90 and 91 of chapter 1 of the code, Manu assigns what each caste should do. “To Brahmanas he assigned teaching and studying (the Veda), sacrificing for their benefit and others, giving and accepting (of alms).”¹¹ “The Kshatriya he commanded to protect the people, to bestow gifts, to offer sacrifices, to study (the Veda), and to abstain from attaching himself to sensual pleasures;”¹² “The Vaisya to tend cattle, to bestow gifts, to offer sacrifices, to study (the Veda), to trade, to lend money, and to cultivate the land.”¹³ “One occupation only the lord prescribed to the Sudra, to serve meekly even these (other) three castes.”¹⁴ This clearly says that only Brahmins and Kshatriyas are allowed to study and educate themselves(the veda) whereas the Shudras are delegated with the work of serving meekly to other three castes envisaging occupational purity. The second aspect of caste which is, blood purity is defined in terms of marriage and sex in the law of Manu. This blood purity according to Manu was that Heterosexual marriage and sex among the people of own caste is permissible whereas intermarriage between varnas is forbidden strictly. Especially if the woman is from a higher caste than that of the man, it is subject to very strict punishment. The script says, “A householder should marry a wife who comes from the same class as he, who has not been married before, and who is younger than he.” Manusmriti acted as a book of jurisprudence and forms the framework for the criminal law justice system with different punishments to people who violate occupational and blood purities. These punishments are in different degrees for different varnas with Shudras receiving the most grievous punishments and the Brahmins enjoying a lot of immunities from these punishments. Comparati-vely, Brahmins are charged mildly when compar-ed to the other three castes despite the crime being same. However, the Brahmins, Kshatriyas and Vaishyas are punished equally if they are charged with the violation of blood purity. This was because Manu was very keen on blood purity that he didn’t want people of lower caste to mingle with the people of higher caste so much so that he said if a Brahmin man undergoes sex with a Shudra woman and begets a child, the man will only go to hell and he loses his Brahmin identity. In Manu’s law, the homicide of a Brahmin or the Brahminicide is considered to be the highest crime of all and even capital punishment did not apply to Brahmin men. Such was the idea proposed by the Manusmriti and its entire accountability can be traced to the Aryan Invasion in India. P.W. Sawant, one of the famous Supreme court judges of India said that if it was not for Aryans, the Indian civilization would have remained far more progressive, even urbanized and relatively prosperous. He also condemns all other historians for having written that there was no civilization in India before the Aryans came here. He lamented that the Aryan’s version of the Indian social system always placed them at the top of the hierarchy, they made Sanskrit the language of day-to-day living and of commerce, which was alien to native Indians. As a consequence, their mastery over the language helped them held themselves as the leaders of the society and let them interpret all the aspects of human life which ultimately ended up being the law in the form of Manusmriti.¹⁵ The worst of all is that they monopolised education and the art of acquiring knowledge. In fact, several great leaders and poets of Indian History have shown their dissent towards the idea proposed by Manusmriti in multiple occasions. Rabindranath Tagore, the first non-white person and Indian to win the Nobel prize once said that the code of Manu needs to be changed inorder to fit the modern day civilization.¹⁶ Dr. Ambhedkar who was an advent crusader of the oppressive caste system, expressed his condemn against caste order in his various writings, speeches and the manifestation of which he gifted us all the Constitution of India which safeguards the population from all such sorts of social evil. Being a Dalit himself, he criticised all Hindu scriptures and especially Mansmriti and the extreme of which was he happened to burn the manuscript of Manusmriti on December 25, 1927 at his native place Mahad in Maharastra. After a century now, even today that day is celebrated as ‘Manusmriti Dahan Divas’ (Manusmriti Immolation Day) by Dalits across India who were the real victims of the evil that the script advocated.¹⁷ In his own words, he once said, “You must destroy the religion of the Shrutis and the Smrutis. Nothing else will avail.
Hinduism is a veritable chamber of horrors and it must die for caste to vanish.
I believe in religion of liberty, equality and fraternity.”¹⁸ Besides this, Ambhedkar has shown his disapproval of Manusmriti through several of his speeches and writings including the Annihilation of Caste, Castes in India, etc. Even the first Vice President and the second President of India Dr. Sarvepalli Radhakrishnan also wished Manusmriti to be edited to match today’s world, thereby he endorsed the viewpoint of Dr. Ambhedkar and Tagore.¹⁹ Concomitantly, there were several leaders who were in favour of Manusmriti and one of them who is hard to believe as a supporter of Manusmriti was Swami Vivekananda. He said that Brahmins are selfless role models and they have a restricted way of life as the higher the caste, greater the restrictions that they should not mingle with the people from lower caste. He said that lower caste people suffer from their own fault of not adopting a Brahminical lifestyle and learning Sanskrit. According to him, Sanskrit is the prestige of India as advocated by Manusmriti.²⁰ However, there are several aspects to his idea which takes much interpretation and ideological thought process. Thus, Manusmriti’s principles were very much based on the caste structure so much so that it can be termed as the Constitution of Caste Order in India.

III. Position of women

Among the many evils that Manusmriti proposed, the major one was the position of women according to Manusmriti. Infact, it had been deemed by the people following it for a very long period of time that Manusmriti is the one ultimate guide or a manual to lead a moral life. In the entire manuscript, women is treated always as dependent, subordinate to men and a transmitter of patriarchal values. Reading some of the direct text of the manuscript will render a good understanding of how it wants a women to be. In chapter 2 of the manuscript, it says, “It is the nature of women to seduce men in this (world); for that reason the wise are never unguarded in (the company of) females.” This specific verse degrades women as a person who always tend to seduce men and people are in great insecurity in the presence of women. This is highly derogatory and completely undermines a women’s position in the society. ²¹ There are also verses in Manusmriti which praises women’s position and tell that, women should be honoured for the welfare of men but all of these get nullified when we read verses that degrades women. In verses 61 and 62 of chapter 3, it says, “For if the wife is not radiant with beauty, she will not attract her husband; but if she has no attractions for him, no children will be born. If the wife is radiant with beauty, the whole house is bright; but if she is destitute of beauty, all will appear dismal”. These two verses indubitably objectify a women with respect to her physical appearance and places the aspect of external beauty as the centre of attracting a man. This also says that in case if the women is not beautiful, then the men of the house would not like her and children won’t be born. Such is the condemnable idea brought forth by Manusmriti regarding women.²² Next Chapter 5 has lot of elements which is antifeministic in nature with high patriarchal values. This scripture is entirely responsible for curtailing women’s autonomy and confine her conduct of life inside her household itself. However, the argument forwarded by supporters of Manusmriti is that Manu encourages us to see this control as “reverence” and “protection” rather than as repression and oppression.²³ “By a girl, by a young woman, or even by an aged one, nothing must be done independently, even in her own house. In childhood a female must be subject to her father, in youth to her husband, when her lord is dead to her sons; a woman must never be independent.”²⁴ This says that a women’s actions can always be dependent on the men of the house and it cannot be independent. The entire manuscript when it talks about women talks it in terms of her relationship with a man, i.e her father, brother and husband whom she should always be dependent on. Also, there is no specific discourse in the entire code about the conduct of a woman who is not married because according to Masnusmriti, an unmarried menstruating woman is seen as a threat to the social equilibrium and a source of religious pollution.²⁵ “She must always be cheerful, clever in (the management of her) household affairs, careful in cleaning her utensils, and economical in expenditure”, said in verse 150 of chapter 5 which implies that women should focus mainly on domestic work and not involve herself in any other profession which is the root of all misogynistic ideas. In verse 165 it says, “She who, controlling her thoughts, words, and deeds, never slights her lord, resides (after death) with her husband (in heaven), and is called a virtuous (wife)”. This verse specifically advocates that she should be completely obedient to her husbands’ words and thereby control her thoughts, words and actions which is a sheer violation of her fundamental rights and freedom. Another interesting fact about the caste and women in Mansumriti is that not all upper caste people enjoyed high privilege, equality among them and superiority. Although women of higher caste were superior to men and women of lower caste, she was still subjected to mistreatment, oppression and discrimination within her own caste for being born as a woman. This also includes objectifying women as depicted in the great epics of Mahabharatha and Ramayana where the wars are fought for women, but in some way they have been objectified in the society.²⁶ Besides, the law of Manu allows women of lower caste to marry a man of upper caste but the reverse is subject to high punishment. By this, it is evident that the law of Mansumriti doesn’t want the women in the house to acquire a higher position to that of the men. Verse 11 and 12 of chapter 13 of the Code also depicts women as a servant in the house who is just meant to serve the husband, prepare food and wash the utensils. In verse 13 of chapter 9, it says, “Drinking (spirituous liquor), associating with wicked people, separation from the husband, rambling abroad, sleeping (at unseasonable hours), and dwelling in other men's houses, are the six causes of the ruin of women.” This verse needs no interpretation that it directly attacks women who wish to drink, who wishes to separate from her husband, her wish in going abroad and even is she feels sleepy at unreasonable hours, it leads to the ruin of her entire life as according to the code of Manu. By and large, the script although in several places glorifies women and suggests to honour her, the majority of the script speaks about objectifying women, snatches her autonomy, confines her within the household and hold high patriarchal values which must find no place in today’s modern society.

IV. Manusmriti and today’s india

What is uncontested is that Manusmriti was widely accepted and followed by the people of that time and it lasted a very long time regardless of whether they liked it or not. As a consequence, it had a colossal influence in determining the structure and functioning of Indian societies which ultimately poisoned people to mistreat women, practice patriarchy and also discriminate people on the basis of caste. To speak in a honest manner, the effects of these ideas can still be seen widely in our social system even after we have moved to a technically liberal and digitally bound society. As The Daily Telegraph newspaper of London reported on January 13, 2004: “Not just in Punjab and Haryana, but in western Uttar Pradesh as well, women are being put to death if they violate the honour of their family and community by marrying a person outside her own caste, community or religion.” However, the extent in which it was practiced and the degree of discrimination has greatly reduced owing to various reasons and the strenuous efforts of great leaders. More importantly, many laws brought in the British India gradually nullified the effect of Manusrmiti if though not completely, atleast in a small amount. Several women centric provisions in the IPC strictly contradict with that of women’s position in Mansmriti. Besides, some exclusive legal interventions to mitigate the shadow of Manusmriti over the Indian social structure were Hindu Widow’s Remarriage Act, 1856, the Hindu Inheritance (Removal of Disabilities), 1928, Hindu Gains of Learning Act, 1930, Hindu Women’s Right to Property Act, 1937. Due to the large time duration of the existence of Mansumriti in the Indian society, the impact it created was not fully nullified even after all these legislation. Thus, Dr. Ambhedkar strenuously and persistently insisted for separate Hindu code bills for administering marital and family affairs of Hindu religion and to attenuate the effect of Hindu scriptures. After a lot of controversies, the bills got passed in 1955 as Hindu Code bills which comprised the Hindu Adoption and Maintenance Act, 1956, Hindu Succession Act, 1956, Hindu Marriage Act, 1955, and Hindu Minority and Guardianship Act, 1956.²⁷ Besides, this the constitution in its golden triangle (article 14, 19 and 21), in article 15, 16 and also in DPSP secured several artciles for the welfare of women and lower caste thus fulfilling a huge attempt to diminish misogyny and caste oppression in India. In independent India, laws like the Indecent Representation of Women Act, 1986 and The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, commonly referred to as the 'POSH Act have tried to undo the effects of Manusmriti. Today, there are a lot of reservation in place for minorities which was the gift of our constitution in article 15(4). Despite several places in India following strict rules with respect to inter-caste marriages and inter-faith religions, a majority of the Indian mass have freed themselves from the stereotypes and Special Marriage Act, 1954 legally backs it. Young population have started considering caste as an evil and they propagate progressive messages for a liberal India. The caste hierarchy with its corresponding delegated occupation have lost its value in the modern-day. In market places, hotels and corporate hospitals, sweepers are now designated as ‘housekeeping staff’. With modern cleaning kits, they now are provided with uniforms to wear and shoes to sport; with caps on their heads, they look more like paramedical staff than the discriminated labours of the vedic period. Even in these pandemic times, sewage workers were given the high privilege of frontline warriors and were also provided with special perks and benefits. And with these changes, much of the caste stigma is diminishing, as even non-Dalits are taking up such jobs. A University of Pennsylvania research team recently surveyed three shopping malls around Delhi, and found more than 60 percent the housekeeping staff were non-Dalit – in which the twice-born accounted for more than 38 percent, the same as Dalits.²⁸ Such is the huge evolution that we have attained after centuries of oppression and mistreatment. Thus, in today’s India we can claim proudly that we as a society have moved far from the ignoble and immoral discourse that our history praised.

V. Conclusion

Former President of the Soviet Union Mikhail Gorbachev once said, “A society should never become like a pond with stagnant water, without movement. That's the most important thing.” The word ‘movement’ as interpreted by the researcher in the context relevant to the subject matter of this research is that society is eternally dynamic and it keeps changing according to the existing needs of the people living in that period of time. Movement refers to the evolution that we attained from centuries of oppression through revolution by people as well as several leaders like Dr. Ambhedkar, E.V.R Periyar and Raja Ram Mohan Roy who lead people from the forefront.

This entire research’s moral is based on this single principle movement is necessary for every civilization to evolve. The Mahar movement, social-religious reform movement by Raja Ram Mohan Roy, the Dalit Movement, the Vaikkam movement all of collectively contributed to the liberal air we are breathing now. This gives us all a very significant message that you got to keep fighting inorder to live more conveniently and that fight is not over until you feel every social evil is eradicated. In such regard, the inference from the current socio-political scenario of India is that the fight is not over. Caste and religion have become a central element for electoral politics now. There are still villages in India that follow stark casteism. Last year, a Punjab man from the Valmiki caste was made to eat human excreta, pay a heavy fine and was publicly beaten up for eloping with a women from a higher caste. Upper Caste Panchayat, a system which Ambedk-ar vehemently supported was held in the Hathras village of Uttar Pradesh in support of the accused in the gang-rape of the 19-year-old Dalit woman from Boolgarhi village on September 14. It is critiqued that the people of that village try to replace the Constitution of India with Mansumriti.²⁹ This is happening now in 21^st century after so many reforms. The loud message that it sends us all is that for the progression of society, we need to educate the masses, make them aware. Empower them legally to protect the minority as how our forefathers effortlessly did in order to take us here. Thus, the researcher appeals to all the readers of this paper to take the movement forward and refrain from being stagnant water to serve justice to the purpose of the makers of the constitution, the struggle of the reformers and to protect every citizen’s individual’s rights.

VI. Bibliography

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Footnotes

1. Author is a student at Tamil Nadu Dr. Ambedkar Law University, India.

2. Chopra, Arushi. "Manusmriti: Everything You Need To Know". Sociology Group: Sociology And Other Social Sciences Blog, 2021, https://www.sociologyg roup.com/manusmriti/. Accessed 26 Mar 2021. ↩

3. Tyagi, Ritwik. "Manusmriti: An Analysis". Medium.Com, 2021, https://medium.com/legal-jumbl e/manusmriti-an-analysis-aad115be357. ↩

4. Jayaram, V. "Manusmriti The Laws Of Manu - Introduction". Hinduwebsite.Com, 2021, https://www.hinduwebsite.com/sacredscripts/hinduism/dharma/manusmriti.asp. Accessed 26 Mar 2021. ↩

5. Gabriel, Roger. "Purushartha: The 4 Aims Of Human Life". Chopra, 2021, https://chopra.com/articles/purushartha-the-4-aims-of-human-life. ↩

6. Stefon, Matt. "Manu-Smriti: Additional Information". Encyclopedia Britannica, 2021, https://www.britannica.com/topic/Manu-smriti/additional-info#history. ↩

7. Buhler, George. The Laws Of Manu. Motilal Banarsidass, 1967. ↩

8. Pattanaik, Devdutt. "What Exactly Is The Manusmriti?". Dailyo.In, 2021, https://www.dailyo.in /lifestyle/hindus-manu-dharmashastra-manusmriti-ve das-devdutt-pattanaik-mythology/story/1/15412.html Accessed 26 Mar 2021. ↩

9. Bhan Prasad, Chandra. "MARKETS AND MANU: ECONOMIC REFORMS AND ITS IMPACT ON CASTE IN INDIA". Center For The Advanced Study Of India University Of Pennsylvania, 2008, pp. 7-8., Accessed 26 Mar 2021. ↩

10. Versus 87, Chapter 1, The Law of Manu ↩

11. Versus 88, Chapter 1, The Law of Manu ↩

12. Versus 89, Chapter 1, The Law of Manu ↩

13. Versus 90, Chapter 1, The Law of Manu ↩

14. Versus 91, Chapter 1, The Law of Manu ↩

15. Sawant, P B. "The Manusmriti And A Divided Nation". The Wire, 2021, https://thewire.in/caste/ma nusmriti-history-discrimination-constitution. ↩

16. C.M. Das, “Philosophy of Ravindra Tagore”, Deep &Deep Publications, pp 211-12 ↩

17. Raut, Madhura. "Why Manusmriti Dahan Divas Is Still Relevant Today | Feminism In India". Feminism In India, 2021, https://feminisminindia.com/2016/12/ 25/manusmriti-dahan-divas-still-relevant/. ↩

18. Speech delivered by Dr. Ambedkar to the Bombay Presidency Mahar Conference, 31st May 1936, Bombay. ↩

19. Mukherjee, Jaya. Tagore & Radhakrishnan, (Janaki Prakshan), pp 107-08. ↩

20. Sabhlok, Sanjeev. "Vivekananda Glorified Brahmins And Chastised Non-Brahmins". Sanjeev Sabhlok's Blog, 2021, https://www.sabhlokcity.com/ 2013/08/vivekananda-glorified-brahmins-and-chastised-non-brahmins/. Accessed 26 Mar 2021. ↩

21. Versus 213, Chapter 2, The Law of Manu ↩

22. Versus 61 and 62, Chapter 3, The Law of Manu ↩

23. Krishnan, Kavita. "One Cannot Be A Feminist In India If You Are Not Fighting The Manusmriti". The Indian Express, 2021, https://indianexpress.com/artic le/opinion/columns/periyar-and-feminism-manusmrit i-on-women-manu-dharma-feminism-6887237/. ↩

24. Versus 147 and 148, Chapter 5, The Law of Manu ↩

25. “The Ultimate Guide To Becoming A 'Good Woman”, Feminism In India, 2021, https://feminism inindia.com/2018/01/11/manusmriti-ultimate-guide-good-woman/. Accessed 26 Mar 2021. ↩

26. Goswami, Shristi. "What Does Manusmriti Say About The Rules And Status For Hindu Women? | Youth Ki Awaaz". Youth Ki Awaaz, 2021, https://ww w.youthkiawaaz.com/2017/10/the-upper-caste-hindu-woman/. Accessed 26 Mar 2021. ↩

27. Rajagopal, G.R. The Story of Hindu Code Bills, Vol. 17 The Journal of Indian Law Institute p. 537-558 (2020). ↩

28. Bhan Prasad, Chandra. "New Order - Himal Southasian". Himal Southasian, 2021, https://www.himalmag.com/new-order/. Accessed 26 Mar 2021. ↩

29. Vaishali. "The Panchayat In Hathras Is Still Trying To Replace The Constitution With Manusmriti". The Wire, 2021, https://thewire.in/caste/hathras-rape-caste-panchayat-constitution-manusmriti. ↩