Chapter XIII. Niyoga

Volume II: Part I pp. 599–607

Chapter Thirteen delves into the complex practice of Niyoga. There exists a great divergence of views concerning its origin and fundamental purpose within the dharmaśāstra tradition. Smṛtikāras, recognizing its sensitive nature, laid down extremely stringent conditions for niyoga to be resorted to, with any breach of these conditions being severely condemned and made punishable. Interestingly, some very ancient writers on dharma did not allow this practice at all, indicating early dissent. Despite these reservations, the Mahābhārata offers numerous examples of niyoga in practice. Later interpretations further refined its scope; some writers posited that texts permitting niyoga applied primarily to śūdras, or specifically to girls who were only promised in marriage to a person but not actually married to him, particularly if the prospective husband had died prematurely. A significant legal and social question that arose was 'to whom the child born of niyoga belonged,' a matter on which three distinct views emerged. Ultimately, Niyoga was expressly forbidden in the Kali age by Bṛhaspati and several other smṛti writers, marking its eventual cessation.

— Synopsis by P.V. Kane, from History of Dharmaśāstra

Chapter XIII. Niyoga

NIYOGA Niyoga—(appointment of a wife or widow to procreate a son from intercourse with an appointed male).

Great divergence of views prevails about the origin and purpose of this practice. It will be best first to begin by examining the most ancient smṛtis that permitted this practice. Gaut.¹ 18. 4-14 have great bearing on this point. Gaut. 18. 4-8 are: ‘a woman whose husband is dead and who desires offspring may secure a son from her brother-in-law. She should obtain the permission of the elders² and have intercourse only during the menstrual period (excluding the first four days). She may obtain a son from a sapiṇḍa, a sagotra, a sapravara or one who belongs to the same caste (when there is no brother-in-law). Some (hold that this practice is allowed) with nobody except a brother-in-law. She shall not bear more than two sons (by this practice)’. Gaut. 18. 11 says that a child begotten at the request of a living husband on his wife belongs to the husbanḍ Gaut. (28. 32) says that such a son is called kṣetraja. The wife is called kṣetra³ (field), the husband of the wife or widow is called kṣetrin or kṣetrika (to whom the wife or widow belongs) and the person appointed to produce offspring is called bījin (one who sows the seed) or niyogin (Vaṣ 17. 64, one who is appointed). The Vaṣ Dh. S. (17. 56-65) similarly prescribes ⁴ the father or brother of the widow (or widow's husband) shall assemble the gurus who taught or sacrificed for the deceased husband and his relatives and shall appoint her (to raise issue for the deceased husband). Let him not appoint a widow who is mad, not master of herself (through grief &c.) or is diseased or is very olḍ (Up to) sixteen years (after puberty is the period for appointing a widow) nor shall an appointment be made if the person who is to approach her is sickly. Let him approach the widow in the muhūrta sacred ⁵ to Prajāpati like a husband, without dallying with her and without abusing or ill-treating her. No appointment shall be made through a desire to obtain ⁶ the estate.' Bauḍ Dh. S. II. 2. 17 (S. B. E. vol. 14, p. 226) defines a kṣetraja son as one who is begotten by another man after permission on the wife of a deceased person or of a eunuch or of one who is suffering from (an incurable disease). Manu (IX. 59-61) says that a widow who is properly appointed may obtain offspring, in case there is total failure of issue, from her brother-in-law or a sapiṇḍa of her husband, that the person appointed should approach her in the dark and should be anointed with ghee and should procreate only one son and never two, while some may procreate two. Bauḍ Dh. S. II. 2. 68-70, Yāj. I. 68-69 and Nārada (stripuṃsā, 80-83) lay down similar ruleṣ Kauṭilya (I. 17, p. 35) says that a king who is old or suffering from (incurable) disease should procreate a son on his queen through a mātṛbandhu or a feudatory chief endowed with qualities similar to hiṣ In another place he says that if a brāhmaṇa dies without leaving a near heir, then a sāgotra or mātṛbandhu may be appointed to procreate a kṣetrajason, who should get the inheritance.⁷ The conditions necessary to allow niyoga were: (1) the husband, whether living or dead, must have no son; (2) the gurus in a family council should decide to appoint the widow to raise issue for the husband; (3) the person appointed must be either the husband's brother, or a sapiṇḍa or sagotra of the same caste); (4) the person appointed and the widow must be actuated by no lust but only by a sense of duty; (5) the person appointed must be anointed with ghee or oil (Nārada,⁸ stripuṁsa, 82), must not speak with or kiss her or engage in sportive dalliance with the woman; (6) this relationship was to last till one son was born (or two according to some); (7) the widow must be comparatively young, she should not be old or sterile or past child-bearing or sickly or unwilling or pregnant (Bauḍ Dh. S. II. 2. 70, Nārada, stripuṁsa 83-84); (8) after the birth of a son they were to regard themselves as father-in-law and daughter-in-law (Manu IX. 62). It is further made clear by the texts that if a brother-in-law has intercourse with his sister-in-law without appointment by elders or if he does so even when appointed by elders but the other circumstances do not exist (e. g. if the husband has a son), he would be guilty of the sin of incest (vide Manu IX. 58, 63, 143, 144 and Nārada, stripuṁsa 85-86) and a son, born of such intercourse, would be a bastard and not entitled to any wealth (Nārada, stripuṁsa 84-85) and that he would⁹ belong to the begetter (Vaṣ Dh. S. 17. 63). Nārada says that if a widow or a male acts contrary to the stringent provisions about niyoga, he or she should be severely punished by the king or otherwise there would be confusioṇ Yāj. II. 234 makes such a person liable to be sentenced to a fine of one hundred paṇas. It will be seen from the above that even in the times of the Dharmasūtras, the practice of niyoga was hedged round with so many restric- tions that it must not have been very much prevalent and instances must have been rather rare.

While ancient Dharmasūtras like Gautama allowed niyoga, there were other dharmasūtras and writers almost as old as Gautama that condemned the practice and forbade it. Ap. Dh. S.¹⁰ II. 10. 27. 5-7 after referring to the view of some that a girl is given to a family in marriage and declaring that that practice ( of polyandry ) is forbidden adds a condemnation of niyoga ' the hand ( of a sagotra is considered to be ) that of a stranger; that if ( the marriage vow ) is transgressed, both ( husband and wife ) certainly go to hell and that the reward obtained from observing the restrictions of the law is preferable to offspring obtained in this manner ( by niyoga ).' Bauḍ Dh. S. II. 2. 38 refers¹¹ to the view of Aupajanghani that it is only the aurasa son that is to be recognized as a son and then quotes three verses ( probably of the same ancient sage ), which are also cited as quotations by Āp. Dh. S. ( II. 6. 13. 6 ) and which call upon husbands to guard their wives and not allow others to procreate sons on the latter, as the sons so procreated will benefit only the begetter. Manu, though at first he describes niyoga, ultimately condemns it in the strongest terms possible ( IX. 64-68 ). He says that among dvijātis a widow should never be appointed to raise issue from another, for by doing so ancient dharma would be violated, that in the mantras relating to marriage there is no reference to niyoga nor is the remarriage of a widow spoken of in the procedure about marriage, that niyoga is a beastly way and was first brought into vogue by king Vena who thereby caused varṇa-samkara, and that since that time good men condemn him who through ignorance appoints a widow to produce offspring. Manu ( IX. 69-70 ) explains the meaning of niyoga by saying that the rules and the ancient texts about niyoga apply or refer to that case only where, after a girl is promised as a bride, the intended bridegroom dies, the brother of the latter is called upon to marry the girl and to have intercourse with her only once during each period till she gives birth to a son who would be the son of the deceaseḍ Though Manu condemned the ancient practice of niyoga, he had to make provision for the kṣetrajā son as regards partition ( IX. 120-121, 145 ). It should be noticed that if the inter- pretation of Manu IX. 69-70 be accepted, the word 'vidhavā' would have to be taken in two different senses in Manu and other texts e. g. in IX. 60 where Manu speaks of niyoga, the word means a girl promised to a bridegroom who died before the marriage ceremony was gone through, while in Manu IX. 64 'vidhavā' means 'a widow whose husband died after marriage was completeḍ' To say the least, this contravenes the canon of Mīmāṁsā interpretation that the same word in the same passage or context should have only one meaning. Bṛhaspati¹² refers to the fact that the Manusmṛti first des- cribed the ancient niyoga and then forbade it and adds that in former ages men possessed tapas and knowledge and could strictly carry out the rules while in dvāpara and kali ages there is great deterioration of power and so men of these times cannot now practise niyoga. The several kinds of sons will be dealt with under vyavahāra.

The Viṣṇu Dh. S. (15. 3) contains an innovation which is not found in the sūtras of Gautama and Vasiṣṭha viz. the ' kṣetraja is one¹³ who is procreated on an appointed wife or widow by a sapiṇḍa of the husband or by a brāhmaṇa.' The Mahābhārata is replete with cases of niyoga. Ādiparva (95 and 103) narrates how Satyavatī pressed Bhīṣma to procreate sons for his younger brother Vicitravīrya (who was dead) from his queens and how ( Ādi. 105 ) when Bhīṣma refused Vyāsa ulti- mately was appointed by Vyāsa's mother Satyavatī and pro- created Dhṛtarāṣṭra and Pāṇḍu. Kumārilabhaṭṭa¹⁴ replies to 'the objector finding fault with Vyāsa by saying that Vyāsa followed Gaut. (18. 4-5) and the urgent request of his mother and besides his tapas saved him from the effects of violation of dharma. Pāṇḍu himself is said to have asked Kunti to procreate sons for him by niyoga from a brāhmaṇa endowed with great tapas (Ādi. 120) and tells her certain stories of niyoga (Ādi. 120-123) and winds up by saying that three sons is ¹⁵ the limit and that if a fourth or a fifth were procreated the woman would be svairiṇī (a wanton woman) and bandhakī (harlot). Ādiparva (chap. 64 and 104) states that when Paraśurāma tried to exterminate the kṣatriyas thousands of kṣatriya widows approached brāhmaṇas for the procreation of sonṣ ¹⁶ Vide Ādiparva, chap. 104 and 177, Anuśāsana, chap. 44. 52-53, Śānti 72. 12 for other references and examples of niyoga. ¹⁷

Owing to the bewildering and often conflicting rules about niyoga in the smṛtis, commentators like Viśvarūpa, Medhātithi, who wrote at a time when niyoga was almost unheard of, made heroic though unsatisfactory efforts to bring order out of chaoṣ Viśvarūpa on Yāj. I. 69 states several views on the point. The first is that niyoga is bad in the present age as opposed to smṛti texts (like Manu IX. 64 and 68) and to the usage of the śiṣṭas (respectable people). The second view was the same as Manu IX. 69 set out above. A third view was that there was an option (as niyoga was both forbidden and allowed). A fourth view (which seems to be the view of Viśvarūpa himself) was that the smṛti texts about niyoga refer to śūdras ¹⁸ (Manu IX. 64 uses the word 'dvijāti') and it was also allowed to royal families, when there was no male to succeed (and only a brāh- maṇa was to be appointed) and Viśvarūpa relies upon two verses of Vṛddhamanu¹⁹ and a gāthā of Vāyu. Viśvarūpa further says that the procreation of sons by Vyāsa from the queens of Vicitravīrya should be paid no heed ( i. e. is not to be relied on ) like the marriage of Draupadī ( to the five Pāṇḍavas). The Mahābhābhārata probably reflects what happened owing to the incessant internecine wars among the princes of India. Whole princely houses must have been slaughtereḍ If niyoga was prevalent among them, the males appointed, who be of the same caste, would have been ordinary soldiers ( kṣatriyas ). The proud princely families very likely thought it below their dignity to associate widowed queens with ordinary kṣatriyaṣ It is possible to hold that they chose brāhmaṇas for appointment, as the latter were deemed to be higher than even kings in the spiritual domaiṇ It is impossible to believe that brāhmaṇas, who had no temporal power, could coerce the proud and warlike caste into choosing brāhmaṇas for niyoga, unless the teaching of the smṛtis fell in with the notions of the ruling houses themselves to some extent at least.

There was difference of opinion as to whom the child of niyoga belongeḍ Vaṣ Dh. S. 17. 6 expressly refers to this divergence. The first view was that the child belonged to the begetter; this view would cut at the very root of the purpose for which niyoga was recommendeḍ Nirukta²⁰ III. 1-3 supports this view and relies on Ṛg. VII. 4. 7-8. Gaut. 18. 9 and Manu IX. 181 state the same rule. Āp. Dh. S. II. 6. 13. 5 says that according to a Brāhmaṇa text the son belongs to the begetter. The second view was that if there was an agreement between the elders of a widow and the person appointed or between the husband himself and the begetter that the child should belong to the husband, then the son belonged to the latter. Vide Gaut. 18. 10-11, Vaṣ 17. 8, Ādiparva 104. 6.²¹ A third view was that the son belonged to both the begetter and the owner of the wife. This is the view of Nārada (stripumsā 58 ), Yaj. II. 127, Manu IX. 53, Gaut. 18. 13. As shown above (in note 1418) niyoga was forbidden in the Kali age by Bṛhaspati and it was included among practices forbidden in the Kali age by several workṣ Vide the Mit. on Yāj. II. 117 and Aparārka p. 97 quoting Brahmapurāṇa.²²

The practice of raising issue from the widow of one's brother or marrying her was a widespread one. Vide Westermarck's ‘History of Human Marriage’ (1921) vol. III. pp. 207-220. In the Ṛgveda²³ X. 40. 2 we read ‘what sacrificer invites you (Aśvins) in his house as a widow invites a brother-in-law to her bed or as a young damsel her lover'. But it is not clear whether this refers to marrying the widow of a deceased brother or to the practice of niyoga. Viśvarūpa (on Yāj. I. 69) thinks that this refers to niyoga. The Nirukta (III. 15) explains Ṛg. X. 40. 2, where in some msṣ the word ‘devara’ is explained as ‘a second husband’ ( dvitīyo varaḥ ). Medhātithi on Manu IX. 66 explains Ṛg. X. 40. 2 as applying to niyoga. According to the sūtras and smṛtis niyoga was entirely different from marriage. In many ancient societies, women were inherited like property. On the death of the eldest brother, his younger brother took the family property as well as his widow. But the Ṛgveda had reached a stage much beyond that. MacLennan thought that the practice of niyoga was due to polyandry. Westermarck combats this view and rightlyso. When niyoga was allowed in the sūtras, polyandry had been either unheard of or forbiddeṇ Jolly in Recht und Sitte (English translation, pp. 156-157) thinks that apart from the religious importance of a son economic motives were at the bottom of the long list of secondary sons, including the kṣetraja. This appears to be quite wrong. The practice of niyoga was a relic from the past and probably owed its origin to several causes, which are now obscure, but one of which was the great hankering for a son evinced by all in Vedic timeṣ Vaṣ Dh. S. (17. 1–6) lends support to this view, since after quoting Vedic passages about the importance of a son for paying off the debt to ancestors and for securing heavenly worlds, he at once proceeds to the description of the kṣetraja. But the economic motive was never put forward by any of the sages, nor could it possibly have been the reason and main-spring of the practice. If many secondary sons were desired for economic reasons, then the same man could have had any number of secondary sonṣ But the dharmaśāstra texts do not allow thiṣ A man who has an aurasa son can have no kṣetraja or adopted soṇ If one kind of son was adopted, then another kind of son could not be adopteḍ So economic motives did not at all form the origin of this practice. Winternitz in J. R. A. S. for 1897 at p. 758 puts forward poverty, paucity of women and the joint family system as the causes of niyoga. There are no data to prove that there was paucity of women in India during historic timeṣ There might have been a paucity of men owing to warṣ Nor do the other two reasons bear close examinatioṇ It is better to say that niyoga was a survival from the remote past, that gradually it became rarer and rarer till in the first centuries of the Christian era it came to be totally prohibiteḍ

अपतिरपत्यलुब्धैर्देवरान् । गुरुप्रसूता नर्तुमंतीयात् । पिण्डगोत्रर्षिसंबंधेभ्यो दत्त्वामृता । नातिद्वितीयाम् । नातिद्वितीयम् । गौतम 18. 4-8. हरदत्त explains नातिद्वितीयम् differently ‘प्रथममुपसत्यस्य द्वितीयं न जनयेदिति’ (i. e. not more than one son is to be so procreated ). ↩
The word गुरु means only the relatives of the husband and not the father of the widow ‘श्वश्रूष्वश्वशुरदेवरानुगो भर्तुसगोत्रा दृष्या न पित्रा-वृषः ; मेघा० on मनु IX. 59. हरदत्त differs and explains गौतम 18. 5 as ‘गुरुभिः पतिपक्षेयैः पितृपक्षेयैर्वा नियुक्ता सती संयुञ्जेत’. Manu (IX. 60-61) shows that some said that only one son could be had by नियोग, while others held that two could be haḍ ↩
Vide मनु IX. 32, 33 and 53 for the words क्षेत्र, क्षेत्रिक, बीजिन; गौतम 18. 11 and Ap. Dh. S. II. 6. 13. 6 employ the word क्षेत्र for wife and Gaut. IV. 3 has the word ‘bījin’. . ↩
ऊर्ध्वै ...... विद्याकर्मगुरुयोनिसंम्बन्धान्निरुपात्य कारयेत् । न सोन्मादामस्वार्था व्याधिता वा नियुज्ययात् । उपायसीभपि । षोडश वर्षाणि । न चे- द्याप्यर्धं स्यात् । वाजपये मुहूर्ते पाणिग्राहावधुपचरेन्नयत्र संग्राहास्य वाक्पाहुरूप्योदपाह- ब्याख्यं ...... रिक्थलोभात्कास्ति नियमः । वसिष्ठ 17. 56-61, 65. ↩
प्राजापत्य मुहूर्ते is the same as ब्राह्म मुहूर्ते viz. the last watch of the night (i. e. ²⁄₅ of an hour before sunrise). Vide वसिष्ठ 12. 47, मनु 4. 92. ↩
The idea is that the widow must not be moved to the act by a mercenary motive. According to धारेम्बर whose views are cited in the धीरमित्रोदय of मित्रमिश्र (p. 633) the widow of a separated sonless man could get the property of her husband only if she submitted to niyoga, otherwise she was to get only maintenance. Dhāreśvara apparently based his view on some ancient textṣ Vaṣ in the last sentence negatives such ⁴ ↩
इन्द्रस्तु व्याधितो वा राजा मातृगुप्तयगुप्तरक्तानाममन्यतेन क्षेत्रे वीज- समुत्पादयेत् । कौटिल्य (I. 17. p. 35); क्षेत्रे वा जनयेदस्य नियुक्ताः क्षेत्रजं सुतम् । मातृ- बन्धुः सगौत्रो वा तस्मै तयदेशोन्नम् ॥ कौटिल्य III. 6 (p. 163). ↩
घृतेनाभ्यज्य गात्राणि तैलेनाविकितेन वा । सुखाभ्युच्चै परिवहन् गात्राणि संस्पृशन् ॥ नारद (स्त्रीपुंस) verse 82. विश्वरूप on या. I. 68 says वृत्तामञ्जनवचनं कामप्रवृत्तिनिरोधार्थम् । तत्प्रथालिङ्गनादि वैकारिकत्वाद् दूरापेनम् । ↩
अनियुक्ता तु या नारी देवराजनयेत्सुतम् ॥ जारजातगरिकवियं तमाहुर्ब्रह्म-वादिनः । नारद (स्त्रीपुंस) 84-85. ↩
अधिजिहे हि परं पाणेः । तद्व्यतिक्रमे खलु पुनरुभयोरनर्कः । नियमरमणं हि वर्षीयानभ्युदय एतस्मादभ्यूणादृतस्यात् । आप. ध. सू. II. 10. 27. 5-7. ↩
An औपजङ्घनि or-ङ्गनि is a teacher mentioned in the वंशा at the end of Br. Up. II. 6 and IV. 6. इदानीमहीयष्यमि स्त्रीणां जनक नो पुरा । यतो यमस्य साधने जनयितुः पुत्रवन्चनम् ॥ श्लोपा: पुत्रे नयति परेत्य यमसादनम् । तस्माद्दार्यां अप्रमता रक्ष्यं तदनुगतं न मा च क्षेत्रे परबीजानि वाप्मुः । जनयितुः पुत्रो भवति सांपराय मोघं चैतद्कृतं ते तनुगतेनम् ॥ बौ. ध. सू. II. 2. 39-41 = आप. ध. सू. II. 6. 13. 6 ( with slight variations ). मत्स्यपुराण 49. 13 has the half verse लेषेपां नयते पुत्रः परेत्य यमसाद्नात् । The last verse occurs in Vaṣ 17. 9 also. ↩
उक्तो नियोगो मुनिना निषिद्धः स्वयमेव तु । युगमादशक्कोयं कर्तुमभ्यर्बिधा- नतः ॥ तपोज्ञानसमायुक्ताः कृतत्रेतायुगे नराः । द्वापरे च कलौ नृणां शक्तिहानिर्विनिर्मिता ॥ अमेकधाः कृताः पुत्रा ऋषिभिश्च पुरातनैः । न शक्यन्तेऽधुना कर्तुं शक्तिहीनैरदनुनैः ॥ बृह० quoted by अपराक on p. 97 (on Yaj. I. 68-69) and by कुल्लूक on मनु IX. 68. ↩
the Smṛtimuktāphalam quotes a passage here, printed 411 → crediting बृहस्पति
नियुक्तोयं सपिण्डेनोत्तमवर्णन बोत्पादितः क्षेत्रजो द्वितीयः । विष्णुधर्मसूत्रम् 15. 3. ↩
The objector says ‘ कृष्णद्वैपायनस्य गृहीतनिद्दिकब्रह्मचर्यस्य विचित्रवीर्य- भार्ययोरुत्पादनमसङ्गः ' ( तन्त्रवार्तिक p. 203 on जै. I. 3. 7 ) and the reply is ' द्वैपायनस्यापि दृष्टनियोगोदापत्तिरप्यल्लिष्टैर्वरतरमुपरितनानुस्मृत्यागतोपबलन- सम्पन्नप्रमाणजपञ्जनं प्राक्तृतमत्वाधिकरणमाजनोदाच-मार्गेणुरपरम् । अप्यादि- वस्तुलक्षणोपपन्नो निर्वडेस कुर्यातैव । तन्त्रवार्तिक p. 208 (on the same सूत्र). ↩
नातश्चतुर्थे प्रसवमापस्तम्बि वदन्मृतः। अतः परं स्वेरिणी स्याद्बन्धुकी पञ्चमे भवेत् ॥ आदिपर्व 123. 77. ↩
ब्राह्मणानां क्षत्रिया राजन् श्रुताभिम्योऽभिचक्रमुः। क्रताद्युतो नरव्राघ्न न कामाप्तांस्तुतो तथा ॥ तेभ्यश्च लेभिरे गर्भं क्षत्रियास्ताः सहस्रशः। आदिपर्व 64. 5-7; एवमन्ये महेष्वासा ब्राह्मणेः क्षत्रिया श्रुवि । जाताः परसधर्मज्ञा महाबलाः ॥ ब्राह्मणे गुणासक्त्युपनिवेषनियमयम् । विचिववीर्यशेषेषु यः 105. 2; परसधर्मे यथेव स्त्री देवरं कुरुते पतिम् । शान्ति 72. 12. ↩
a passage here stands at आदिपर्व P01_U06_A064.7 →
Vide Dr. Winternitz's paper (Notes on Mahābhārata) in J. R. A. S. 1897 pp. 716-732 'for Niyoga in the great epic'. ↩
एवं तात्स्थद्वाणां नियोगाधिकार उक्तः । विश्वरूप at the end of his coṃ on I. 69. A little above विश्वरूप remarks that there is a usage of नियोग among śūdraṣ ↩
तथा च वृ‌द्धमनुः। शूदामेव धर्म्ये पत्न्यो प्रेतेऽपत्यसंश्रयः । लोभा‌न्मूढैर्विवाह्याभिर्क्षत्रिये बर्षते ॥ वायुप्रोक्ता तथा गाथा ष‌ड्वत्स्य मर्नि‌पिणः । विद्माणां न नियोगोऽस्ति प्रेते पत्न्यो न वेदनम् ॥ and the gāthā is अकार्यमेतत्सुज्ञेयये । उ‌ह्यते वा मृते पत्न्यौ देवरेण विशेषतः ॥ विश्वरूप. ↩
तद्यथा जनयितुः प्रजा एवमधीर्योयं चाडुद्वाद‌हिरिप्यामः । निरुक्त III. 1. ↩
उत्पत्वादपिष्ठः पुत्र इति हि ब्राह्मणम् । आप. ध. सू. II. 6. 13. 5; पाणिग्रा‌हस्यैव तनय इति चेवेदु नियन्त्रम् । आदिपर्व 104. 6. ↩
उक्तं च । यथा नियोगधर्मों नो नाखस्थावधोषि धा। तथोद्धारविभागोपि नैव संप्रत्ति वर्तते ॥ इति । मिता० on या. II. 117; कीणां पुनर्विवाहस्तु देवरान्नुसंततिः । स्वातन्त्र्यं च कलियुगे कर्तव्यं न कदाचन ॥' ब्रह्मपुराण quoted by अपरार्क p. 97. ↩
को वां शयुत्रा विधवेव देवरं मर्ये न योषा कृणुते सधस्थ आ. ॥ ॠ. X. 40. 2 ↩

Chapter XII. The Duties of a Widow, Some Privileges of Women and the Purda System Chapter XIV. Remarriage of Widows