SEM-III PROJECT

NAME OF THE STUDENT: SUJEET KATELIYA

ROLL NUMBER: 23-A
NAME OF THE SUBJECT : FAMILY LAW - II
TOPIC: AN OVERVIEW OF SATI TRADITION WITH
EMPHASIS ON SATI PREVENTION ACT, 1987
SUBMITTED TO : PROF. SUSHMA MHASKE & PROF.
NAVANITHA WARRIOR
 ACKNOWLEDGEMENT
I would like to take this golden opportunity to express my gratitude to one and all without whom
it would not be possible to complete the project. Firstly, I would like to express my gratitude to
Prof. Sushma Mhaske and Prof. Navanitha Warrior for guiding me throughout the project. I
also feel thankful and express my gratitude to our Principal Dr. Priya J. Shah for giving me this
opportunity. I Would also like to thank my college
SVKM’S Jitendra Chauhan college of law and the University of Mumbai to allow me to enhance
my skills and get an amazing experience. All the respected teachers provided me with their vital
support and guidance because of which I could make this project. This project helped me find my
capabilities and enhanced my research skills. I would also like to express my sincere thanks to my
family for their continuous support and encouragement.

SUJEET TULSIBHAI KATELIYA

23-A

1|Page
 TABLE OF CONTENTS

SR. PARTICULARS PAGE

NO NO
1) Introduction 3-4

2) Historical Background of sati tradition in India 5-6

3) British Regulation 7

4) Modern time 8-9

5) Enforcement Of India’s 1987 Sati Law 10-11

6) Shortcomings 11-12

7) Indian Penal Code 13

8) Cases 14-15

9) Conclusion 16

10) Bibliography 17

2|Page
 INTRODUCTION
Sati or suttee was a historical practice in which a widow sacrifices herself by sitting atop her
deceased husband's funeral pyre. Although it is debated whether it received scriptural mention in
early Hinduism, it has been linked to related Hindu practices in the Indo-Aryan-speaking regions
of India which diminished the rights of women, especially those to the inheritance of property. A
cold form of sati, or the neglect and casting out of Hindu widows, has been prevalent from ancient
times. Greek sources from around 300 BCE make isolated mention of sati, but it probably
developed into a real fire sacrifice in the medieval era within the northwestern Rajput clans to
which it initially remained limited, to become more widespread during the late medieval era.1

Sati or suttee is the ancient Indian and Nepalese practice of burning a widow on her husband's
funeral pyre or burying her alive in his grave. This practice is associated with Hindu traditions.
The name is taken from the goddess Sati, wife of Shiva, who burned herself to protest her father's
ill-treatment of her husband. The term "sati" can also apply to the widow who commits the act.
The word "sati" comes from the feminine present participle of the Sanskrit word asti, meaning
"she is true/pure." While it has been most common in India and Nepal, examples have occurred in
other traditions from as far afield as Russia, Vietnam, and Fiji.

According to custom, Hindu sati was supposed to be voluntary, and often it was seen as the proper
finale to a marriage. It was considered to be the signature act of a dutiful wife, who would want to
follow her husband into the afterlife. However, many accounts exist of women who were forced
to go through with the rite. They may have been drugged, thrown into the fire, or tied up before
being placed on the pyre or into the grave.

In addition, the strong societal pressure was exerted on women to accept sati, particularly if they
had no surviving children to support them. A widow had no social standing in traditional society
and was considered a drag on resources. It was almost unheard-of for a woman to remarry after
her husband's death, so even very young widows were expected to kill themselves.2

https://en.wikipedia.org/wiki/Sati_(practice)#:~:text=The%20Commission%20of%20Sati%20(Prevention,that%20of
%20burying%20her%20alive.
2
https://www.thoughtco.com/what-is-sati-195389

3|Page
The term sati is derived from the original name of the goddess Sati, also known as Dakshayani,
who self-immolated because she was unable to bear her father Daksha's humiliation of her (living)
husband Shiva. Sati as practice is first mentioned in 510 CCE, when a stele commemorating such
an incident was erected at Eran, an ancient city in the modern state of Madhya Pradesh. The
custom began to grow in popularity as evidenced by the number of stones placed to commemorate
satis, particularly in southern India and amongst the higher castes of Indian society, despite the
fact that the Brahmins originally condemned the practice (Auboyer 2002). Over the centuries the
custom died out in the south only to become prevalent in the north, particularly in the states of
Rajasthan and Bengal. While comprehensive data are lacking across India and through the ages,
the British East India Company recorded that the total figure of known occurrences for the period
1813 - 1828 was 8,135; another source gives the number of 7,941 from 1815 - 1828, an average
of 618 documented incidents per year. However, these numbers are likely to grossly underestimate
the real number of satis as in 1823, 575 women performed sati in the state of Bengal alone
(Hardgrave 1998).3

3
https://kashgar.com.au/blogs/history/the-practice-of-sati-widow-burning

4|Page
 Historical Background of Sati Tradition in India

The exact origin of the Sati is unknown, but scholars say that it emerged for two reasons first, for
the upper-class funerals; it added more grandeur to their funerals, and the idea of cremating the
items of the deceased with him is applied here, as his wife is considered one of his possessions.
Second to keep the women safe from the enemy invading their territory, for example, Mughals
invading the Rajput territory. It is said that when a soldier of the Rajput army was killed in the
battle, his wife would immolate herself on his funeral pyre to prevent herself from falling into the
hands of Mughals. In India, only the people of Rajput caste living in Rajasthan perform mass
suicide called Jauhar when defeated in battles. For example, Queen Padmini and her womenfolk
committed mass suicide to prevent the Muslim sultan of Delhi Alauddin Khilji from capturing
them. Because of this incident, many believe that Sati came into existence just to avoid women
from being captured by Muslims who invaded India. Among princes and the people of the higher
caste, widow burning was regarded as a collective act. For example, in 1724, sixty-six women
were burned alive at the funeral of Ajit Singh of Marwar Jodhpur, and eighty-four women were
sacrificed at the funeral of Budh Singh, a king of Bundi. There is a resemblance in Sati and Jauhar,
and the only difference is Jauhar was done by Rajput widows at the end of a defeated battle, while
Sati by a normal Hindu widow in a religious context.8 A widow gains dignity and power if she
decides to die alongside her husband, and by doing that, she brings honour to her husband's family.
Therefore, by her dignified sacrifice, the widow can avert being despised and procure glory for
herself and her family.

Jorg Fisch, in his book Journal of world history, gives a different reason for the origin of Sati. He
says "Only where either some kind of classes, estates, castes, or other social strata or a clear-cut
division of labour with matching differences of power between the sexes, age groups, or races exist
can custom of following into death develop." In this way, he concludes that we should not look
too far back in history for the origin of Sati. He says it was a private matter where lovers or spouses
either die together or follow each other into death disregarding man or woman. He further adds
that when society became aware of this custom, it tried to control or limit it by incorporating it
into a public ceremony, and prescribed who can die and who cannot. Both Jorg and Dorothy say

5|Page
that this custom was not only practised in India but also in different parts of the world such as the
Greeks, Egyptians, Chinese, Finns, and some American Indians used to practice it.

Greek visitors who visited north India while travelling the world, states that Sati was practiced in
4th-century B.C11 but others say that this tradition has been practiced since 510 AD, and there are
hints in religious texts that indicates it was present even before 510 AD and practiced by only
certain tribes.12 In the 8th century, the practice was not followed by many people. It was just a
starting point that actively encouraged women to perform Sati. However, in the 13th century, it
became a common practice.13 We can conclude two things from this, first the conflict between
scholars about the origin of Sati. Second, if we consider the first Sati was performed by goddess
Sati, we don't know when was the second act was performed. If we accept that Sati was originated
in 4thcentury B.C then how do we explain the gap from 4th-century B.C to 5th century A.D. After
that up to 1000 A.D, Sati incidents were rare, we can even say that Sati spread all over India by
the religious text after 13th century and became a common practice and spread all over India.

Sati is all about a woman dying alongside her husband. Some scholars say that Sati tradition was
obligatory, but some say that after the death of their husbands, the wives were given a day to decide
about Sati, and if she chose to die alongside her husband, then she can lie beside her husband's
dead body, or jump in the fire or sit in a cross-legged position with the head of her husband on her
lap and burn in the fire with him. After the Sati ritual, all the family members and all her
community would worship and deify her and build a temple of her in the place where she was
immolated. People from neighboring villages and cities would visit this temple in a pilgrimage to
worship Sati. Many people oppose this Sati ritual and say this practice is ancient and outdated.
Many argue that Sati is not mentioned in Hindu religious texts, and there is no evidence of Sati in
these Hindu religious and sacred texts. Therefore, it is illogical and against human nature. But
contrary to their argument and beliefs, Sati is mentioned in the Hindu sacred text, which I will cite
below.4

4
https://dergipark.org.tr/

6|Page
 BRITISH REGULATION

Before the British, the Dutch and the French too banned Sati but the efforts bore fruit only under
the Colonial Government under the Lord William Bentick after 1829. He was not ready to accept
the sharp rise in the deaths due to Sati in his province Bengal and he got the support of the
missionaries and especially an educated section of Hindus led by Raja Ram Mohan Roy.

The Sati Regulation Act, XVII of 1829 came into force after much discussions and was called, “A
Regulation for declaring the practice of suttee or burning or burying alive of the widows of Hindus,
illegal and punishable by the criminal courts” Thus, the Act was a major breakthrough in the fight
against Sati as it became a criminal offence and it was punishable where or not the Sati was illegal
or legal. Section 1 of the Act which laid down the intent just like the preamble enunciated, “The
practice of suttee or of burning or burying alive, the widows of Hindus is revolting to the feelings
of human nature: it is nowhere enjoined by the religion of the Hindus as an imperative duty...” The
zamindars (landlords), officers and local agents became the eye of the authorities and were
required to report any case of intended Sati. The failure of the officer to willfully not report the
incident led to a fine of Rs 200 or a 6-month imprisonment.5

5
Andrea Major, ‘Sati: a Historical Antholog’y (Oxford University Press 2007).

7|Page
 MODERN TIME

LEGISLATIVE STATUS OF SATI IN PRESENT-DAY INDIA

Following the outcry after the sati of Roop Kanwar, the Indian Government enacted the Rajasthan
Sati Prevention Ordinance, 1987 on 1 October 1987. and later passed the Commission of Sati
(Prevention) Act, 1987.

The Commission of Sati (Prevention) Act, 1987 Part I, Section 2(c) defines sati as:

The burning or burying alive of –

(i) any widow along with the body of her deceased husband or any other relative or with any article,
object or thing associated with the husband or such relative; or

(ii) any woman along with the body of any of her relatives, irrespective of whether such burning
or burying is claimed to be voluntary on the part of the widow or the women or otherwise

The Prevention of Sati Act makes it illegal to support, glorify or attempt to die by sati. Support of
sati, including coercing or forcing someone to die by sati, can be punished by death sentence or
life imprisonment, while glorifying sati is punishable with one to seven years in prison.

Enforcement of these measures is not always consistent.[142] The National Council for Women
(NCW) has suggested amendments to the law to remove some of these flaws.[143] Prohibitions of
certain practices, such as worship at ancient shrines, is a matter of controversy.

CURRENT SITUATION

There were 30 reported cases of sati or attempted sati over a 44-year period (1943–1987) in India,
the official number being 28. A well-documented case from 1987 was that of 18-year-old Roop
Kanwar. In response to this incident, additional legislation against sati practice was passed, first
within the state of Rajasthan, then nationwide by the central government of India.

In 2002, a 65-year-old woman by the name of Kuttu died after sitting on her husband's funeral
pyre in Panna district of Madhya Pradesh. On 18 May 2006, Vidyawati, a 35-year-old woman
allegedly committed sati by jumping into the blazing funeral pyre of her husband in Rari-Bujurg
Village, Fatehpur district, Uttar Pradesh.

8|Page
On 21 August 2006, Janakrani, a 40-year-old woman, burned to death on the funeral pyre of her
husband Prem Narayan in Sagar district; Janakrani had not been forced or prompted by anybody
to commit the act.

On 11 October 2008 a 75-year-old woman, Lalmati Verma, committed sati by jumping into her
80-year-old husband's funeral pyre at Checher in the Kasdol block of Chhattisgarh's Raipur district;
Verma killed herself after mourners had left the cremation site.

Scholars debate whether these rare reports of sati suicide by widows are related to culture or are
examples of mental illness and suicide. In the case of Roop Kanwar, Dinesh Bhugra states that
there is a possibility that the suicides could be triggered by "a state of depersonalization as a result
of severe bereavement", then adds that it is unlikely that Kanwar had mental illness and culture
likely played a role. However, Colucci and Lester state that none of the women reported by media
to have committed sati had been given a psychiatric evaluation before their sati suicide and thus
there is no objective data to ascertain if culture or mental illness was the primary driver behind
their suicide. Inamdar, Oberfield and Darrell state that the women who commit sati are often
"childless or old and face miserable impoverished lives" which combined with great stress from
the loss of the only personal support may be the cause of a widow's suicide.6

https://en.wikipedia.org/wiki/Sati_(practice)#:~:text=The%20Commission%20of%20Sati%20(Prevention,that%20of
%20burying%20her%20alive.

9|Page
 ENFORCEMENT OF INDIA’S 1987 SATI LAW

The passing of The Commission of Sati (Prevention) Act, 1987 was seen as an unprecedented
move to many in India, and was hailed as a new era in the Women's rights movement.
Unfortunately, the enforcement of this law has been lacklustre at best.

The Commission of Sati (Prevention) Act, 1987 appears to be facing its greatest challenge on the
aspect of the law which penalises the glorification of Sati in Section 2 of this Act:

"(i) The observance of any ceremony or the taking out of a procession in connection with the
commission of Sati; or

(ii) The supporting, justifying or propagating of the practice of Sati in any manner; or

(iii) The arranging of any function to eulogise the person who has committed Sati; or

(iv) The creation of a trust, or the collection of funds, or the construction of a temple or other
structure or the carrying on of any form of worship or the performance of any ceremony thereat,
with a view to perpetuate the honour of, or to preserve the memory of, a person who has committed
Sati."

The punishment for glorifying sati is a minimum one-year sentence that can be increased to seven
years in prison and a minimum fine of 5,000 rupees that can be increased to 30,000 rupees. This
Section of the Act has become heavily criticised by both sides of the Sati debate. Proponents of
Sati argue against it, claiming the practice to be a part of Indian culture. Simultaneously, those
against the practice of Sati also question the practicality of such a law, since it may be interpreted
in a manner so as to punish the victim. Enforcement aside, the existence of the law is debated as
well.

The nation continues to witness a cultural divide in regards to their opinions of Sati, with a great
deal of the glorification of this practice occurring within it. The Calcutta Marwari have been noted
to follow the practice of Sati worship, yet the community alleges it to be a part of their culture and
insist they be permitted to follow their practices. Additionally, the practice is still fervently revered
in parts of rural India, with entire temples still dedicated to previous victims of Sati.7

7
https://en.wikipedia.org/wiki/Sati_(practice)

10 | P a g e
India is steeped in a heavily patriarchal system and their norms, making it difficult for even the
most vigilant of authorities to enforce the 1987 Act. An instance of this can be seen in 2002 where
two police officers were attacked by a mob of approximately 1000 people when attempting to stop
an instance of Sati. In India, the powers of the police remain structurally limited by the political
elite. Their limited powers are compounded by "patriarchal values, religious freedoms, and
ideologies" within India.

India is steeped in a heavily patriarchal system and their norms, making it difficult for even the
most vigilant of authorities to enforce the 1987 Act. An instance of this can be seen in 2002 where
two police officers were attacked by a mob of approximately 1000 people when attempting to stop
an instance of Sati. In India, the powers of the police remain structurally limited by the political
elite. Their limited powers are compounded by "patriarchal values, religious freedoms, and
ideologies" within India.

Furthermore, enforcement of this law is easily circumnavigated by authorities by writing off cases
of Sati as acts of suicide. This is attributed to not only a hesitancy to prosecute when the
punishment remains so severe, but also another indication of a deeply patriarchal society.8

SHORTCOMINGS

The Act though created with an intention does not fully suffice the purpose of its enactment. It has
turned to be what has been called by the experts an empty legislation. The Central Government
failed to address the concerns of the women groups and further the amendments to make the laws
more stringent have also failed.

First of all, the widow under the act is also treated as a criminal, whereas on the other hand the
woman who has been forced to commit Sati or being forced to commit Sati is nothing but a victim
in the hands of religion and societal pressure. The focus of the Act should have been the abettors
along with the onlookers who are blinded by the religious practices. Further, the act as seen in the
case of Roop Kanwar, takes a lot of time to decide the matter whereas the provisions of the act
clearly state the special courts be set up and the matter like this shall be dealt without any delay.

8
https://en.wikipedia.org/wiki/Sati

11 | P a g e
The issue of donations and funds for glorification are not usually given by the individuals but
rather big companies who are trying to evade the taxes. The Income Tax Act should remove the
tax exemption to the donations made to the charitable institutions which have been set up as a
result of Sati.

One of the other loopholes that the Act suffers from is that under Section 16 the burden of proof
has been reversed and makes it difficult to catch hold of the actual offender. Had the parliament
instead of specific legislation amended the provisions for homicide and murder in such a way, the
laws and their application would have been stricter.

One of the recent cases that came to light was of woman named Charan Shah who is said to have
committed Sati in Uttar Pradesh. The matter could not be investigated and subsequently no FIR
was filed. It was reported to the police that she jumped on the funeral pyre of her husband and the
villagers could not be held liable under the act. Due to the fact that the investigation could not be
conducted, no one was found guilty and another woman became of victim of oppressive religious
custom. This case shows the ineffectiveness of the act in dealing with actual cases.

If the act of 1829 be compared to that of 1987, we have seen a lot of positive changes but still have
some drawbacks. Firstly, the act of 1829 did not include as punishment the glorification of Sati
which can be inferred as a right to freedom to profess their religion under Article 25 of the Indian
Constitution. These provisions however have remained just on paper and experts have pointed out
the Act of 1829 had a stronger thrust as it created a fear in the minds of not just the people but
especially the authorities as they were involved in the fight against Sati and failure to report an
incident became a personal liability of the authorities. This led to creation of a moral fear in the
minds of the people and led to better governance.

According to Ninad D. Seth, instead of outlawing sati, the Government should try and bring about
a social transformation so that people abhor such acts. He has observed: “To root out the evil
practice of Sati, it is necessary to understand the sentiments behind it. Alas, the state has chosen
the easy way out by legislating instead of creating conditions for social transformation.”9

9
Ahmed (n 1).

12 | P a g e
 INDIAN PENAL CODE

The Charter of 1833 empowered the East India Company to make laws for British India with
giving consideration to the India customs and traditions. The job of drafting a criminal code which
shall be applicable to the entire Indian sub-continent was given to T.B. Macaulay. Though he was
in support of the ‘Sati Pratha’ but the effect of the high-class Brahmins in the making of the penal
code lead to the addition of Exception 5 to the Section 300 of the IPC where if the death occurred
due to his own consent, it came under the exception. Despite this, taking of life is prohibited under
the IPC but the punishment varies according to the facts and circumstances of each case.

If the facts of the case were such that the burying or burning to the woman is proved to be
involuntary, it automatically falls under the category of murder under section 300. Even if the act
was proved to be voluntary, the death amounted to culpable homicide or abetment to suicide. There
have been cases where a poisonous substance or intoxicant was found in the body followed by Sati
was punished under Section 305, the punishment for which is equal to that of a murder. In case of
a failed Sati, the person helping in the due course or pressurizing the woman was charged for
attempt to murder under Section 307 along with attempt to commit culpable homicide not
amounting to murder and abetment to suicide, the punishment of which was one year in prison.

Under the provisions of the IPC the one who abets the act of Sati shall also be liable for his actions.
Abetment has different forms and can be achieved in the form of instigation, doing or omission of
an act, intentional aiding or willfully concealing of the facts. The person pressing the trigger of
Sati shall not be left scot free and the provisions of the IPC have adequately covered the offences.

13 | P a g e
 CASES

In the case of Gaurav Jain v. Union of India10 , the Supreme Court laid down guidelines and
gave instructions to the government for the prevention of any illegal activities involving women
and rehabilitation through various measures. Making them financially independent shall not lead
to acts such as Sati being committed as the women would become self-sufficient and have an
identity of their own. Vocational training was also highlighted by the court in order to ensure
employment to the women.11

In the case of Ch. Khemi Shakti Mandir Trust v. Union of India,12 the meaning of Sati was
clarified by the court where it was held that scope of the Act was only limited to the definition of
Sati as given under the Act and any other definition of Sati shall not be under the purview of the
Act. Further, another question of law that was involved in the case was whether there can be revival
of proceedings under the Act if the same as already been dealt by the High Court. This too was
clarified by the court that the Act provides for continuation of only those proceedings which are
pending and not for revival of proceedings.

Another recent case where the court dealt with the Commission of Sati (Prevention) Act, 1987 was
in the case of Swami Agnesh v. Union of India13 . The petitioner in this case filed a writ petition
seeking directions to the Central Board of Film Certification, to take “appropriate steps to stop
glorification of the practice of ‘Sati’ by deleting the relevant scenes from the film “Padmaavat”.
The petitioner also placed reliance on two articles in the newspaper to show the negative effect it
shall have on the society. The court highlighted the disclaimer of the film which said that the film
in no way was trying to harm anyone’s belief or culture and the intention of the filmmaker was not
to encourage or supports Sati in any way. Furthermore, the film was given the due certification by
the authority before the release and if the petitioner had any grievance, the same should have been
brought before the notice of Board of Film Certification at the relevant time. The articles relied
upon were considered the personal opinion of the authors and the same do not become a substantial

10
Gaurav Jain v. Union of India, AIR 1997 SC 3021.
11
Ahmed (n 1).
12
Ch. Kemi Shakti Mandir Trust v. Union of India [2010] 15 SCC 768.
13
Swami Agnesh v. Union of India [2018] AIR (Delhi) 138.

14 | P a g e
material. Therefore, in view of the Disclaimer towards the starting of the film and that the required
certification was present with the filmmaker, the petition was disposed of any merit.

It was held in the case of Tejsingh v. State 14

, that the person assisting the commission of Sati
shall also be liable under Section 306. In the present case, after the death of her husband Mt.
Saraswati was burnt on the funeral pyre of her husband. People from different villages also
gathered to witness the scene. Investigation revealed that the decision was taken beforehand and
the police could not stop the procession of more than 1500 people who canted ‘Sati ki Jai’ and
‘Sati Mata ki Jai ho’. The close 5 relatives played an important role in the burning and were
sentenced only 6 months imprisonment which was enhanced by the High Court and the accused
were sentenced one year’s imprisonment under Section 147, one year’s imprisonment under
Section 342 and five-year imprisonment under Section 306.

It was held in the case of King Emperor v.Vidyasagar Pande15 that the person assisting a widow
to commit Sati is guilty of Abetment of Suicide under Section 306 of IPC. It was further held by
the court that the person cannot anticipate a miracle to save the widow and escape the criminal
liability by citing the reason that he expected that funeral pyre would not be ignited by a human
agency.

14
Tejsingh v. State[1958] AIR (Rajasthan) 169.
15
King Emperor v. Vidyasagar Pande [1929] ILR (Patna) 74.

15 | P a g e
 CONCLUSION

If we were to analyze the present situation with respect of the practice of Sati, we shall be finding
people justifying the practice in the name of tradition and customs. Whereas, this practice of Sati
is more than just a custom as it represents the position of women in the society even in the modern
times. Even more dangerous than sati itself is the fact that the glorification and exaggeration of the
act which is backed by religion.

While we discuss the problem, nothing can be done to undo the past but significant changes can
be made to ensure that the current and future generations are not caught in this evil practice of Sati.
We must collectively raise our voice against the very patriarchy which in the first place led to the
emergence of such practices. Tracing the roots, we found that Sati was based on the helpless
widows who were mainly Hindus. Their only goal was marriage and their whole life revolved
around marriage, which needs to be changed in a way to bring in individualism to ensure that the
wives can separate themselves from their husband and look themselves like human beings.

All efforts of education and socialupliftments are bound to go down the drain if we continue to
supports the patriarchy and the notion that an individual woman cannot exist without the protection
of any male. A society’s level of progress is measured by the freedom and rights which are available
to its women. Even today, after more than 73 years of Independence from the British rule, we are
not able to get freedom from the patriarchal system and the status of women has not been what it
should be.

The incidents of widow burning, which are nowadays lesser than before, are a reminder of our
indifference attitude of the society towards the women. We should all come together and publicly
condemn such acts and state that such evil practices have no space not just in Hinduism but also
in every other religion. The efforts shall be put by the government of the country along with the
people, only then we can see some change. The financial dependence of the women needs to reduce
to the extent that she should not be concerned about her expenses if she needs to take an important
decision in her life. This shall help to build self-confident and help her becoming an individual
with goals and aspirations and not just a shadow of her husband.

16 | P a g e
 BIBLIOGRAPHY

• Nehaluddin Ahmad, ‘Sati Tradition - Widow Burning in India: A Socio-legal Examination’

(2009) 2 Web JCLI <http://webjcli.ncl.ac.uk/2009/issue2/ahmad2.html> accessed 3 May
2020.
• Mamata Rao, Law Relating to Women and Children (2nd edn, EBC Publication 2008).
• P.V Kane, History of Dharmasastra, (Bhandarkar Oriental Research Institute 2006).
• Romila Thapar, ‘In History’ [1988] 342 Seminar 463.
• Ananda Cooramaswamy, The Dance of Siva (Noonday Press 1971).
• V.P Verma, Modern Indian Political Thought (Lakshmi Narian Agarwal 2017)
• Andrea Major, Sati: a Historical Anthology (Oxford University Press 2007)
• John Stratton Hawley, Sati, the Blessing and the Curse (Oxford University Press 1994)
• Rani Jethmalani, ‘Widows, Abandoned and Destitute Women’ (1991) 46 ILHR 72
• The Commission of Sati (Prevention) Act 1987
• T.K Raj Lakshmi, ‘Sati and the verdict’ [2005] 21 Frontline 5

17 | P a g e