The study of jurisprudence started with the Romans.

The term Jurisprudence is derived from Latin

word 'Jurisprudentia' which means either "Knowledge of Law" or "Skill of law".
The word "juris" means law and prudentia mean knowledge, science or skill. Thus
Jurisprudence signifies knowledge or science of law and its application. In this
sense, Jurisprudence covers the whole body of legal principles in the world.

1) Jurisprudence: Meaning:

Jurisprudence in its widest sense means. " knowledge of the law" but
in its limited sense evolution and explanation of general principles upon which
actual rules of law are based. It is mainly concerned with the rules of external
conduct which people are compelled to obey. Therefore sometimes it is said that
jurisprudence is that Jurisprudence is that science which gives us knowledge
about "law" but the term law we always use in its abstract sense i.e. not in the
sense of concrete statutes but in the sense of principles underlying law. Thus, for
example, there are various branches of law existing in the modern legal system
such as contract, crime, trust, properties, companies, labour etc. In jurisprudence,
we have to study the basic principles of each of these branches and we are not
concerned with the detailed rules of these laws. We definitely study these laws in
detail when we study those branches of law separately. Jurisprudence examines
the general principles of law, therefore, Jurisprudence may be considered to be
the study and systematic arrangements of the general principles of law.

2) Definition of Jurisprudence:

It is very difficult to define term 'jurisprudence', However, several attempts

were made in this context to define the term. Some of the definitions of the term
"jurisprudence" given by various eminent jurists as under -

I) Austin :
 Austin was the first jurist to make jurisprudence as a science. He
defines 'jurisprudence' as "the philosophy of positive law." He opines that the
appropriate subject to jurisprudence is a positive law i.e. law as it is (existing law).
In other wosdrerds, jurisprudence is not a moral philosophy but it is a scientific
and systematic study of the existing, actual and positive law has distinguished
from natural, ideal or moral law.

Austin divides jurisprudence into two classes. Viz 'general Jurisprudence

and Particular Jurisprudence. According to him 'General Jurisprudence is the
philosophy of positive law. On the other hand 'particular jurisprudence is the
science of any such system of positive law as now actually obtains or once actually
obtained in a specifically determined nation or specifically determined nations.

Criticism:

Austin's definition criticised by Salmond and Holland and other Jurists on

the ground that it is not proper and appropriate to classify as the general
Jurisprudence and Particular Jurisprudence.

- cfr

II) Holland:

An English Jurist Sir Thomas Erskine Holland defines, Jurisprudence as, "
Jurisprudence is the formal science of positive law'" According to him
jurisprudence should only concern itself with the basic principles of concepts
underlying in any natural system of law.

Criticism:
 Many eminent jurists have criticised the definition of Holland that
jurisprudence is the formal science of positive law. It is not free from defects. The
question arises what is a formal science? Holland himself explains that by the
term 'formal' he means that jurisprudence concerns itself with human relations
which are governed by the rules of law rather than the material rules themselves,
for the latter are the subject of legal exposition, criticism or compilation rather
than jurisprudence.

III) Salmond:

Salmond defines Jurisprudence as, " Jurisprudence is the science of the first
principle of the civil law."

According to Salmond Jurisprudence can be defined in two senses (1) in the

'Generic Sense' jurisprudence can be defined as Science of Civil Law' and (2) in the
'Specific sense' Jurisprudence can be defined as the science of the first principle of
civil law.

The Civil law consists of rules applied by Courts in the administration of

Justice. Salmond agrees with both Austin and Holland only to the extent that
jurisprudence is 'a science, a systematic study of basic principles of legal systems.

Criticism :

Salmond's Definition has been criticised on the ground that he has narrowed
down the field of jurisprudence by saying that it is a science of civil law and hence
covers only particular legal system.

IV) Keeton:
 Keeton Defines jurisprudence as " the study and systematic arrangement of
the general principles of law.

V) Roscoe Pound:

Dean Roscoe Pound defines jurisprudence as " the science of law, using
the term law in the juridical sense, as denoting the body of principles recognised
or enforced by public and regular tribunals in the administration of justice".

VI) Dr K. C. Allen:

Jurisprudence is the scientific synthesis of all the essential principles of

law.

VII) G.W. Paton:

Jurisprudence is a particular method of study, not the law of one

country, but of the general notion of law itself.

VIII) Julius Stone:

"Jurisprudence is the lawyer's extraversion. It is the lawyer's

examination of the precepts, ideals and techniques of the law in the light derived
from present knowledge in disciplines other than the law.

IX) Gray :
 According to John Chipman Gray " jurisprudence is the science of law, the
statement and systematic arrangement of the rules followed by the Court and the
principles involved in those rules."

Criticism:

Stone has Criticised Gray's Definition and said that Gray has failed to
determine any province of jurisprudence rather he has reduced jurisprudence to
merely a matter of arrangement of rules.

X) Ulpian:

Ulpian a Roman Jurist defines jurisprudence as " Jurisprudence is the

knowledge of things divine and human, the science of just and unjust."

XI) Dr M.J. Sethna:

Jurisprudence is a study of fundamental legal principles including their

philosophical, Historical and sociological bases and analysis of legal concepts.

XII) H.L.A Hart:

A legal system consists of primary and secondary rules. These rules

explain the nature of law and provides key to the science of jurisprudence. He
viewed Jurisprudence as a science of law in a border perspective by co-relating
law and morality.

From the above definitions of Jurisprudence, it could be seen that there

is no commonly agreed definition of Jurisprudence. Each Jurist guided by his own
consciences but since the conception of the term law till the beginning of the 20th
century, a new approach to the study of law in relation to society is given. Some
jurist, therefore, treats law as "social engineering" an instrument to bring social
change. Thus the function of law is the sup lement to social sciences.

Ownership in jurisprudence
Jurists have defined ownership in different ways. All of them accept the right of
ownership as the complete or supreme right that can be exercised over anything.
Thus, according to Hibbert ownership includes four kinds of rights within itself.
 Right to use a thing
 Right to exclude others from using the thing
 Disposing of the thing
 Right to destroy it.
Austin’s definition
Austin while defining ownership has focused on the three main attributes of
ownership, namely, indefinite user, unrestricted disposition and unlimited
duration.
 Indefinite User
 Unrestricted Disposition
 Unlimited Duration
The abolition of Zamindari system India , the abolition of privy purses,
nationalization of Bank etc. are some example of the fact that the ownership can
be cut short by the state for public purpose and its duration is not unlimited.
Austin’s definition has been followed by Holland. He defines ownership as plenary
control over an object. According to him an owner has three rights on the subject
owned
 Possession
 Enjoyment
 Disposition
Planetary control over an object implies complete control unrestricted by any law
or fact. Thus, the criticism levelled against Austin’s definition would apply to that
given by Holland in so far as the implication of the term “plenary control” goes.
Salmond’s Definition:
According to the Salmond ownership vests in the complex of rights which he
exercises to the exclusive of all others. For Salmond what constitute ownership is
a bundle of rights which in here resides in an individual. Salmond’s definition thus
point out two attributes of ownership:
 Ownership is a relation between a person and right that is vested in him
 Ownership is incorporeal body or form
MODERN LAW AND OWNERSHIP
Under modern law there are the following modes of acquiring ownership which
may be broadly classed under two heads,viz,.
Original mode
Derivative mode
The original mode is the result of some independence personal act of the acquire
himself. The mode of acquisition may be three kinds
 Absolute when a ownership is acquired by over previously ownerless object
 Extinctive, which is where there is extinctive of previous ownership by an
independence adverse act on the part of the acquiring. This is how a right
of easement is acquiring after passage of time prescribed by law.
 Accessory that is when requisition of ownership is the result of accession.
For example, if three fruits, the produce belongs to the owner unless he has
parted with to the same. When ownership is derived from the previous
version of law then it is called derivate acquisition. That is derived mode
 takes place from the title of s prior owner. It is derived either by purchase,
exchange, will, gift etc.Indian Transferee Acts of property rules for the
transfer of immovable property, Sale of goods Acts for the transfer of
property of the firm and the companies Act for the transfer of company
property.
SUBJECT MATTER OF OWNERSHIP
Normally ownership implies the following:
 The right to manage
 The right to posses
 The right to manage
 The right to capital
 The right to the income
CHARACTERISTICS OF OWNERSHIP
An analysis of the concept of ownership, it would show that it has the following
characteristics: Ownership ma either be absolute or restricted, that is, it may be
exclusive or limited. Ownership can be limited by agreements or by operation of
law.The right of ownership can be restricted in time of emergency. An owner is
not allowed to use his land or property in a manner that it is injurious to others.
His right of ownership is not unrestricted.The owner has a right to posses the
thing that he owns. It is immaterial whether he has actual possession of it or not.
The most common example of this is that an owner leasing his house to a tenant.
Law does not confer ownership on an unborn child or an insane person because
they are incapable of conceiving the nature and consequences of their acts.
Ownership is residuary in character. The right to ownership does not end with the
death of the owner; instead it is transferred to his heirs. Restrictions may also be
imposed by law on the owner’s right of disposal of the thing owned. Any
alienation of property made with the intent to defeat or delay the claims of
creditors can be set aside.
KINDS OF OWNERSHIP
There are many kinds of ownership and some of them are corporeal and
incorporeal ownership, sole ownership and co-ownership, legal and equitable
ownership, vested and contingent ownership, trust and beneficial ownership, co-
ownership and joint ownership and absolute and limited ownership.
Corporeal and Incorporeal Ownership
Corporeal ownership is the ownership of a material object and incorporeal
ownership is the ownership of a right. Ownership of a house, a table or a machine
is corporeal ownership. Ownership of a copyright, a patent or a trademark is
incorporeal ownership. The distinction between corporeal and incorporeal
ownership is connected with the distinction between corporeal and incorporeal
things. Incorporeal ownership is described as ownership over tangible things.
Corporeal things are those which can be perceived and felt by the senses and
which are intangible. Incorporeal ownership includes ownership over intellectual
objects and encumbrances.
Trust and Beneficial Ownership
Trust ownership is an instance of duplicate ownership. Trust property is that
which is owned by two persons at the same time. The relation between the two
owners is such that one of them is under an obligation to use his ownership for
the benefit of the other. The ownership is called beneficial ownership. The
ownership of a trustee is nominal and not real, but in the eye of law the trustee
represents his beneficiary. In a trust, the relationship between the two owners is
such that one of them is under an obligation to use his ownership for the benefit
of the other. The former is called the trustee and his ownership is trust
ownership. The latter is called the beneficiary and his ownership is called
beneficial ownership.
Legal and Equitable Ownership
Legal ownership is that which has its origin in the rules of common law and
equitable ownership is that which proceeds from the rules of equity. In many
cases, equity recognizes ownership where law does not recognize ownership
owing to some legal defect. Legal rights may be enforced in rem but equitable
rights are enforced in personam as equity acts in personam. One person may be
the legal owner and another person the equitable owner of the same thing or
right at the same time.
The equitable ownership of a legal right is different from the ownership of an
equitable right. The ownership of an equitable mortgage is different from the
equitable ownership of a legal mortgage.
There is no distinction between legal and equitable estates in India. Under the
Indian Trusts Act, a trustee is the legal owner of the trust property and the
beneficiary has no direct interest in the trust property itself. However, he has a
right against the trustees to compel them to carry out the provisions of the trust.
Vested and Contingent Ownership
Ownership is either vested or contingent. It is vested ownership when the title of
the owner is already perfect. It is contingent ownership when the title of the
owner is yet imperfect but is capable of becoming perfect on the fulfillment of
some condition. In the case of vested ownership, ownership is absolute. In the
case of contingent ownership it is conditional. For instance, a testator may leave
property to his wife for her life and on her death to A, if he is then alive, but if A is
dead to B. Here A and B are both owners of the property in question, but their
ownership is merely contingent. It must, however, be stated that contingent
ownership of a thing is something more than a simple chance or possibility of
becoming an owner. It is more than a mere spes acquisitionis. A contingent
ownership is based upon the mere possibility of future acquisition, but it is based
upon the present existence of an inchoate or incomplete title.
Sole Ownership and Co-ownership
Ordinarily, a right is owned by one person only at a time. However, duplicate
ownership is as much possible as sole ownership. When the ownership is vested
in a single person, it is called sole ownership; when it is vested in two or more
persons at the same time, it is called co-ownership, of which co-ownership is a
species. For example, the members of a partnership firm are co-owners of the
partnership property. Under the Indian law, a co-owner is entitled to three
essential rights, namely
 Right to possession
  Right to enjoy the property
 Right to dispose
Co-ownership and Joint Ownership
According to Salmond, “co-ownership may assume different forms. Its two chief
kinds in English law are distinguished as ownership in common and joint
ownership. The most important difference between these relates to the effect of
death of one of the co-owners. If the ownership is common, the right of a dead
man descends to his successors like other inheritable rights, but on the death of
one of two joint owners, his ownership dies with him and the survivor becomes
the sole owner by virtue of this right of survivorship.
Absolute and Limited Ownership
An absolute owner is the one in whom are vested all the rights over a thing to the
exclusion of all. When all the rights of ownership, i.e. possession, enjoyment and
disposal are vested in a person without any restriction, the ownership is absolute.
But when there are restrictions as to user, duration or disposal, the ownership will
be called a limited ownership. For example, prior to the enactment of the Hindu
Succession Act, 1956, a woman had only a limited ownership over the estate
because she held the property only for her life and after her death; the property
passed on to the last heir or last holder of the property. Another example of
limited ownership in English law is life tenancy when an estate is held only for life.
Jurisprudence - Ownership
Jurisprudence - Ownership
Legal experts have defined ownership in different ways.
All of them accept the right of ownership as the complete or supreme right that
can be exercised over anything.
According to Hibbert ownership includes four kinds of rights within itself.
 · Right to use a thing
 · Right to exclude others from using the thing
 · Disposing of the thing
  · Right to destroy it.

Austin’s definition:
Austin while defining ownership has focused on the three main attributes of
ownership, namely, indefinite user, unrestricted disposition and unlimited
duration.
 · Indefinite User
 · Unrestricted Disposition
 · Unlimited Duration

State can interfere in the ownership. The abolition of Zamindari system in India ,
the abolition of privy purses, Nationalization of Bank and Companies, etc. are
some example of the fact that the ownership can be cut short by the state for
public purpose and its duration is not unlimited.
Austin’s definition has been followed by Holland. He defines ownership as
plenary control over an object. According to him an owner has three rights on
the subject owned
 · Possession
 · Enjoyment
 · Disposition

Planetary control over an object implies complete control unrestricted by any

law or fact. Thus, the criticism levelled against Austin’s definition would apply
to that given by Holland in so far as the implication of the term “plenary
control” goes.
Salmond’s Definition:
According to the Salmond - ownership vests in the complex of rights which he
exercises to the exclusive of all others. For Salmond what constitute ownership
is a bundle of rights which in here resides in an individual. Salmond’s definition
thus point out two attributes of ownership:
 · Ownership is a relation between a person and right that is vested in
him
 · Ownership is incorporeal body or form

MODERN LAW AND OWNERSHIP

Under modern law there are the following modes of acquiring ownership which
may be broadly classed under two heads, viz,.
1. Original mode:
2. Derivative mode:
Original mode:
The original mode is the result of some independence personal act of the
acquire himself. The mode of acquisition may be three kinds
1. Absolute: when a ownership is acquired by over previously ownerless
object.
2. Extinctive: which is where there is extinctive of previous ownership by an
independence adverse act on the part of the acquiring. This is how a right
of easement is acquiring after passage of time prescribed by law.
3. Accessory: that is when requisition of ownership is the result of accession.
For example, if three fruits, the produce belongs to the owner unless he
has parted with to the same. When ownership is derived from the
previous version of law then it is called derivate acquisition. That is
derived mode takes place from the title of prior owner. It is derived either
by purchase, exchange, will, gift etc.

Indian Transferee Acts of property rules for the transfer of immovable property,
Sale of goods Acts for the transfer of property of the firm and the companies Act
for the transfer of company property.
SUBJECT MATTER OF OWNERSHIP
Normally ownership implies the following:
· The right to manage
· The right to posses
· The right to capital
· The right to the income
CHARACTERISTICS OF OWNERSHIP
An analysis of the concept of ownership, it would show that it has the following
characteristics:
Ownership may either be absolute or restricted, that is, it may be exclusive or
limited. Ownership can be limited by agreements or by operation of law. The
right of ownership can be restricted in time of emergency. An owner is not
allowed to use his land or property in a manner that it is injurious to others. His
right of ownership is not unrestricted. The owner has a right to posses the thing
that he owns. It is immaterial whether he has actual possession of it or not. The
most common example of this is that an owner leasing his house to a tenant.
Law does not confer ownership on an unborn child or an insane person because
they are incapable of conceiving the nature and consequences of their acts.
· Ownership is residuary in character. The right to ownership does not end
with the death of the owner; instead it is transferred to his heirs. Restrictions
may also be imposed by law on the owner’s right of disposal of the thing
owned. Any alienation of property made with the intent to defeat or delay the
claims of creditors can be set aside.
Kinds of Ownership
There are many kinds of ownership and some of them are corporeal and
incorporeal ownership, sole ownership and co-ownership, legal and equitable
ownership, vested and contingent ownership, trust and beneficial ownership,
co- ownership and joint ownership and absolute and limited ownership.
Ownership may be classified under the following heads :
I. Corporeal and incorporeal ownership;
2. Sole ownership and co-ownership;
3. Legal and equitable ownership;
4. Trust and beneficial ownership; .
5. Vested and contingent ownership; and .
6. Absolute and limited ownership;
Corporeal and Incorporeal Ownership
Corporeal ownership is the ownership of a material object and incorporeal
ownership is the ownership of a right. Ownership of a house, a table or a
machine is corporeal ownership. Ownership of a copyright, a patent or a
trademark is incorporeal ownership. The distinction between corporeal and
incorporeal ownership is connected with the distinction between corporeal and
incorporeal things.
Incorporeal ownership is described as ownership over tangible things. Corporeal
things are those which can be perceived and felt by the senses and which are
intangible.
Incorporeal ownership includes ownership over intellectual objects and
encumbrances.

Trust and Beneficial Ownership

Trust ownership is an instance of duplicate ownership. Trust property is that
which is owned by two persons at the same time. The relation between the two
owners is such that one of them is under an obligation to use his ownership for
the benefit of the other. The ownership is called beneficial ownership. The
ownership of a trustee is nominal and not real, but in the eye of law the trustee
represents his beneficiary.
In a trust, the relationship between the two owners (one is trustee owner and
another is beneficiary owner) is such that one of them is under an obligation to
use his ownership for the benefit of the other. The former is called the trustee
and his ownership is trust ownership. The latter is called the beneficiary and his
ownership is called beneficial ownership.
In simple terms, A trust is an instance of duplicate ownership namely, trust
ownership and beneficial ownership. In a trust certain property is given in trust
or confidence to a person or a definite group of persons to be held under an
obligation for the benefit of some other persons or group of persons.
Trust is defined as an obligation annexed to the ownership of property, and
arising out of a confidence reposed in and accepted by the owner, or (b)
declared and accepted by him for the benefit of the other.
Legal and Equitable Ownership
Legal ownership is that which has its origin in the rules of common law and
equitable ownership is that which proceeds from the rules of equity. In many
cases, equity recognizes ownership where law does not recognize ownership
owing to some legal defect.
Legal rights may be enforced in rem but equitable rights are enforced in
personam as equity acts in personam. One person may be the legal owner and
another person the equitable owner of the same thing or right at the same time.
The equitable ownership of a legal right is different from the ownership of an
equitable right. The ownership of an equitable mortgage is different from the
equitable ownership of a legal mortgage.

There is no distinction between legal and equitable estates in India. Under the
Indian Trusts Act, a trustee is the legal owner of the trust property and the
beneficiary has no direct interest in the trust property itself. However, he has a
right against the trustees to compel them to carry out the provisions of the
trust.
For information, but in English law recognises two forms of ownership—legal
and equitable. In England before the passage of Judicature Acts of 1873, and
1875 there existed two kinds of Courts with two quite distinct jurisdictions.
These two Courts were known as the Common Law Courts and the Equity
Courts.
The rights reognised and protected by the Common Law Courts were called legal
or Common Law Rights and the rights enforced by Equity Courts were known as
equitable rights.
Legal ownership is, therefore, that ownership which was or recognised by the
rules of Common Law, while equitable ownership is that which originated from
the rules of equity.
Equitable ownership was thus not recognised by the Common Law Courts. The
Chancery or Equity Courts recognised legal ownership as well as the equitable
ownership.
Keeton says, “This quality of legal and equitable ownership arises, whenever
one person holds the legal title to property, the beneficial enjoyment of which is
vested in another. Thus the legal owner is he whom the Common law could
designate as the owner ; the Equitable owner is that person whom the Court of
Chancery would formerly have protected in the enjoyment of a thing.”
Vested and Contingent Ownership
Ownership is either vested or contingent. It is vested ownership when the title
of the owner is already perfect. It is contingent ownership when the title of the
owner is yet imperfect but is capable of becoming perfect on the fulfillment of
some condition.
In the case of vested ownership, ownership is absolute. In the case of
contingent ownership it is conditional.
For instance, a testator may leave property to his wife for her life and on her
death to A, if he is then alive, but if A is dead to B. Here A and B are both
owners of the property in question, but their ownership is merely contingent. It
must, however, be stated that contingent ownership of a thing is something
more than a simple chance or possibility of becoming an owner. It is more than
a mere spes acquisitionis. A contingent ownership is based upon the mere
possibility of future acquisition, but it is based upon the present existence of an
inchoate or incomplete title.
It is vested when the owner’s title is already perfect; it is litingent when his title
is as vet imperfect, but is capable of becoming perfect on the fulfilment of some
condition or contingency. Vested own-ership is absolute, contingent ownership
is conditional. It is subject to conditions and it may be made to commence or
cease upon the ascertainment that a certain fact does not exist.
Thus, I may be the owner of a piece of land on condition of paying a certain
fixed sum of money annually to the State. My ownership is thus conditional on
the annual payment of the money.
Contingent ownership is not spes acquisitionis—Simple chance or mere
possibility of becoming owners—but more than that. It is more than a mere
future possibility but the existence of an inchoate or incomplete title in the
present, capable of achieving completion and perfection on the happening of a
given contingency in future.
The conditions on which ownership depends may be either ‘condition
precedent’ or ‘condition subsequent’. A condition precedent is one by the
fulfilment of which a title is completed ; a condition subsequent is one on the
fulfilment of which a title already completed is extinguished. In the former case
ownership which was formerly conditional becomes ab-solute. In the later case
the ownership which is already lost conditionally, is lost absolutely. In case of a
condition subsequent ownership is not contingent but vested. For the condition
attached to the ownership it is not with regard to commencement of ownership
but with regard to continence of it.
Sole Ownership and Co-ownership
Ownership may be either sole or duplicate. When it is vested in one person it is
called sole owner-ship ; when it is invested in two or more persons at the same
time, it is called duplicate ownership.
The chief instances of duplicate ownership are ;
(i) Co-ownership;
(ii) Trust and beneficial ownership;
(iii) Legal and equitable ownership;
(iv) Vested and, contingent ownership.
Co-ownership that is to say, ownership shared by several persons with equal or
co-ordinate results may be of two kinds, namely:—
(a) Joint ownership, and
(b) Ownership-in-common.
(a) ‘Joint ownership’ is that where on death of one of the co-owners the whole
right ensures for the benefit of surviving co-owner or co-owneers, until at last
when the last survivor of the joint owners, dies, it would devolve on his heirs.
The heirs of a predeceased co-owner will not get any share at all in the property
of the joint owner.
(b) “Ownership-in-common” is that where, on the death of one of the co-
owners, his heirs step into his shoes.
Ordinarily, a right is owned by one person only at a time. However, duplicate
ownership is as much possible as sole ownership. When the ownership is vested
in a single person, it is called sole ownership; when it is vested in two or more
persons at the same time, it is called co-ownership, of which co-ownership is a
species. For example, the members of a partnership firm are co-owners of the
partnership property.
Under the Indian law, a co-owner is entitled to three essential rights, namely
 · Right to possession
 · Right to enjoy the property
 · Right to dispose

Co-ownership and Joint Ownership

According to Salmond, “co-ownership may assume different forms. Its two chief
kinds in English law are distinguished as ownership in common and joint
ownership. The most important difference between these relates to the effect
of death of one of the co-owners. If the ownership is common, the right of a
dead man descends to his successors like other inheritable rights, but on the
death of one of two joint owners, his ownership dies with him and the survivor
becomes the sole owner by virtue of this right of survivorship.
Absolute and Limited Ownership:
An absolute owner is the one in whom are vested all the rights over a thing to
the exclusion of all. When all the rights of ownership, i.e. possession, enjoyment
and disposal are vested in a person without any restriction, the ownership is
absolute. But when there are restrictions as to user, duration or disposal, the
ownership will be called a limited ownership.

For example, prior to the enactment of the Hindu Succession Act, 1956, a
woman had only a limited ownership over the estate because she held the
property only for her life and after her death; the property passed on to the last
heir or last holder of the property. Another example of limited ownership in
English law is life tenancy when an estate is held only for life