According to Muslim law, dower is an essential component of marriage. Dower is another word for the Arabic word Mehr. Muslim women have a special entitlement known as dower, which allows them to receive money from their husband in advance of, during, or at any point after marriage. Although a Muslim wife's security status in a marriage is improved by dower, dower is not always due to a Muslim wife.

There are some situations where a Muslim woman is not entitled to dower. The focus of this study is to understand the whole concept of Muslim law. This research also provides a brief explanation on importance and objective of dower. The article also covers the subject of how a Muslim woman might be able to reclaim an underpaid dower as well as some relevant case law.

Muslim Marriage: Mehr

While nikah (marriage) in the Arab culture refers to a wide variety of sex relationships, it has a very specific legal meaning in Muslim law. [1] It is a contract that makes sexual activity and childbirth acceptable. [2]Marriage is an institution created for the protection of society and so that people might safeguard themselves from immorality and unchastity, according to an old book cited by Ameer Ali.

Therefore, the objective is to support traditional family values and the legalization of children. The acceptance of a modified form of polygamy serves to distinguish it from the modern concept of marriage. Form And Capacity
Islam's marriage laws stand out for the simplicity they have. Marriage can be formed without any formalities. There are no irksome formalities or special rites. The two necessary conditions are acceptance (qubul) and offer (ijab). When one contracting party makes a statement and the other party reciprocates at the same meeting, the marriage is legally constituted. If both parties are competent, the acceptance and declaration may be made by either their agents or the parties.[3]

The guardians may lawfully enter a marriage contract on behalf of their wards in the event of legal incompetency, such as unsoundness of mind or minority. Regarding the form, the following prerequisites must be met. In Hanafi law, witnesses are not required, and in the case of Shia law, acceptance (qubul) by the opposite party (or by the guardians, as the case may be) is all that is required until there are enough witnesses.[4]

There must be no ambiguity, doubt about the intention to marry, or merely a commitment to marry in the future; the words must convey with a high degree of confidence that a marriage has been contracted.

A marriage cannot be constituted by a proposal made at one meeting and an acceptance made at another meeting; both must be declared at the same meeting for it to be valid. In Muslim law, a simple betrothal does not confer any rights. In other words, the verbal contract must be fulfilled in person at the exact same time and place.[5] Another crucial component is consideration. Mehr is the property or the amount of money that the bride's future husband must give her as a consideration for their marriage. Its main object is to give the bride a feeling of financial security both during and after the marriage.

Muslim marriages must have the voluntary agreement of both parties. If consent was obtained through coercion, fraud, misrepresentation, error, or undue influence, the marriage is deemed null and void.[6]

Lastly a Muslim man is not permitted to marry any of the following women due to consanguinity, which is defined as a blood tie. His mother, grandmother, granddaughter, or both. Marriage with a woman that is forbidden by the consanguinity relationship is null or void whether the woman is his sister, niece, grandaunt, or aunt. Muslim law also forbids any marriages to close relatives.[7] His wife's daughter, his wife's mother or grandmother, his father's wife, and his son's wife.

A marriage with women prohibited under affinity is void. Marriage must be performed in presence of legal and legal witnesses. Shia law does not mandate the presence of witnesses, and marriages performed without them are nonetheless recognised as legal. The Sunni legal system places a premium on witness presence. A witness must be of sound mind and major, and there must be at least two female and one male witnesses.[8]

1. Agreements
   The parties are free to agree on terms before, during, or even after the wedding because a Muslim marriage is a contract. When the parties to a Muslim marriage are unable of making decisions for themselves, their respective guardians may do so on their behalf. Such agreements are enforceable even though the husband and wife are not parties to them. Agreements are illegal if they include clauses that go against Islamic beliefs or are irrational. The existence of an illegal contract has no impact on whether a marriage is legal, but the condition is void and unenforceable.
   
   These agreements cannot be executed because they are against Islam. The marriage contract would be voidable if any clause was unconstitutional unless marriage was consummated. However, if the marriage is actually consummated, it will remain valid and any illegal conditions will be nullified, preventing the marriage from becoming void.
    
2. Capacity
   A marriage contract may be entered into by any Muslim who is of sound mind and has attained majority status. The majority is reached at puberty. Contrary to popular belief, which holds that a person reaches majority age at the age of 15, the Hedaya specifies that the earliest age for a female is 9 years male is 12 years. In a Shia case, the Privacy Council concluded that a female becomes of legal age at nine. Only the guardians of minors have the authority to marry them.[9] Even though the marriage is legal, it is still subject to dissolution. In the eyes of the law, a girl who marries before attaining puberty is not recognised to have married, and the marriage is consequently void.
    
3. Option of Puberty
   If a Muslim minor has been wed by a guardian while still a minor, the minor can renounce the marriage once they reach adulthood. This is referred to as the "option of puberty" or khiyar al-bulugh. The father, grandpa, or any other guardian may give such a minor in marriage. The prohibition that prevented a juvenile girl from exercising her right to puberty when she was married by her father or grandpa under the previous law has been lifted by statute. Only the wife will be able to use this option if she brings a legal action under the Act.
   
   It cannot be exercised by her in a suit by her husband for restitution of conjugal rights or in any other proceedings.[10] If a girl marries while still a minor, she is entitled to a divorce if she can show that her father or another guardian gave her in marriage, that the marriage took place before she turned 15, that she repudiated the marriage before she attained the age of 18; and the marriage has not been consummated. When a marriage is consummated before the wife reaches puberty, she still has options.
   
   The age of puberty is set at fifteen in clause (vii) of section 2 of the Dissolution of Muslim Marriages Act of 1939 without the possibility of rebuttal. Although it deals with the option that arises at puberty, this clause only mentions age and says nothing about puberty. The only reasonable interpretation of this law is that a woman who was given in marriage by her guardian before turning fifteen years old is permitted to repudiate her marriage for a period of three years after turning fifteen and before turning eighteen.[11]
   
   The same right to dissolve a marriage exists for a spouse who was married while still a minor, but there is no set time limit in which he must exercise it. When he reaches majority, he can exercise the option, and ratification is implied by dower payments or cohabitation.
   
   While it has been ruled that a wife's right is not determined by mere consummation if she was unaware of it, the right of repudiation is lost upon consummation. If a girl does not repudiate the marriage within a reasonable amount of time after reaching puberty and being notified of the right, the right is likewise forfeited in that situation. According to the statute, the wife must use the option before turning 18 years old.[12]
   
   The marriage is not dissolved by the simple act of exercising the right to repudiate. Prior to the court's confirmation of the repudiation, the marriage is still valid, and if either spouse passes away, the other has the right to inherit.
    
4. Iddat
   In accordance with Muslim law, a woman is barred from getting married for a predetermined period (known as iddat) when her marriage is ended by death or divorce. During this period of continence, which is imposed upon her upon the dissolution of a marriage in the interest of certainty of paternity, a woman is required to live in isolation and refrain from indulgences.[13]
   
   Where there has been cohabitation, iddat must be observed. Cohabitation may be legal, as in a marriage that has been consummated, or it may be illegal, as in illicit sexual activity. If pregnancy results from illicit sexual activity, iddat must be observed.
   
   The term of iddat is three courses, or if the lady is pregnant, until delivery, if the marriage has been consummated and is ended by divorce. The iddat period is four months and ten days or, if the woman is pregnant, until delivery, whichever is longer, if the marriage is dissolved by death. Iddat must be respected in the event of a death if the marriage has not been consummated, but not in the case of a divorce.[14]

Dower

Before Islam, there were two kinds of wedding presents. When the husband visited the wife but did not bring her home, a present given to the wife was known as a sadiqa, or female friend, and a gift given to the lady on marriage was known as a sadaq. This sort of marriage is known as a beena marriage.[15] For dowries in Islam, the terms "sadaq" and "maher" are interchangeable. The two words, however, used to be extremely different from one another; maher was presented to the wife's parents, but sadaq was given to the wife.

Dower is a sum of money or other property that the husband promises to pay to the wife as consideration for the marriage. Even in cases when the dower isn't fixed during the marriage ceremony, the wife is nevertheless given the right to dower under the law. Dower is merely required by law as a token of respect for its purpose, so mentioning it is not essential for a marriage to be valid.

For the same reason, a marriage can also be valid even though the man entered into the contract with the special conditions that there would be no dower.[16] According to Justice Mahmood in the case of Abdul Kadir v. Salim[17], under Muslim law, dower is a sum of money or other property that the husband promises to pay to the wife as consideration for marriage; if the amount of money or other property is not fixed during the marriage ceremony, the wife has the right to demand dower.

The marriage is not nullified if the payment of dower isn't specified before or during the marriage ceremony. After much discussion, Abdul Rahim made the correctly observed that dower is not a consideration for marriage and has no affect on the legality of a marriage; rather, it is an obligation on part of the husband as a sign of respect for his wife. Dower payment is still practiced under Muslim marriage law. It is still necessary to pay the dower in Muslim marriages. According to case law, women have special rights to pursue unpaid dower, and their husbands are compelled by law to do so.

1. Classification of Dower
   As we have seen, dower is due regardless of whether the amount has been fixed. According to Ali, there cannot be a marriage without maher. Therefore, at initially, dower may be either specified or unspecified. The latter situation it refers to it as mahr al- mithl, suitable dower, or literally, "the dower of the like." If the dower has been specified, the question of whether it is promt (mu'ajjal) or deffered (muwajjal) may come up. There are so two different kinds of dowers in Islam. Unspecified dower or proper dower (mahr al-mithl) and specified dower (al-mahr al-musamma) There are two types of dowers: prompt (mu'ajjal) and deffered (muwajjal).[18]
   
   Specified dower (al-maher al-musamma)
   The maher is often fixed at the time of the wedding, and the qazi performing the ceremony enters the sum in the register. Alternatively, a regular contract called a kabin nama may exist with a number of conditions. The sum maybe fixed either at the time of marriage or later, and a father; s contract on behalf of a minor son is binding on the minor.[19]
   
   In Hanafi law, a father who stipulates on behalf of his minor son is not held personally accountable for the maher; however, this is not the case in Ithana Ashari law. In the case of Syed Husain v. Farzand Hasan[20]. A Shia father had made himself as surety for the payment of his underage son's maher. After he died it was held that his estate was responsible for paying his sons, Maher. Each heir was therefore held personally liable for a portion of the wife's claim in accordance to the share they had received from the deceased.[21]
   
   The husband will be compelled to pay the whole amount after it has been set, regardless of how excessive the court may find it given the husband's financial situation. However, if the court determines that the amount is excessive, only a fair amount will be ordered in Oudh.[22]
   
   Unspecified dower (mahr al-mithl)
   In other words, if there is a marriage, then the husband has a legal obligation to pay the dower; this obligation is independent of any agreement the parties may have made. Any amount, no matter how excessive, may be stipulated for the dower. But in the absence of an agreement, what principles should be used in determining the dower amount?
   
   The proper or customary dower of a woman is to be fixed with reference her own personal qualifications and social position of her father's family. The husband's social standing and financial resources barely factor in. The Hedaya establishes the important rule that must be observed: "Her age, beauty, fortune, understanding, and virtue." Therefore, in an Islamic marriage, a wife's rights are protected, and every effort is made to guarantee that her economic condition is in line with her own social position.[23]
   
   Maher is an essential aspect to the status of marriage under Mussulman law, to the point that when it is unspecified at the time the marriage is contracted the law declares that it must be adjudged on definite principles.
    
2. Prompt (mu'ajjal) and deferred (muwajjal) dower
   The question of when and how much is payable when the dower is specified. Here, two relatively ambiguous terms are used, and it is important to make a thorough distinction between them. The Arabic word mu'ajjal, which means "that which has been hastened or given a priority in point of time," is the technical name for "prompt" dower. However, the word muwajjal means "delayed, deferred" and comes from a root that also meaning to delay or postpone.[24]
   
   When the woman demands it, prompt dower is paid right away after the marriage, but deferred dower is paid at the dissolution of the marriage or upon the happening of a certain event. When dower is determined, it is usual to divide it into two equal portions and specify that one shall be given immediately or upon demand and the other upon the husband's death, a divorce, or the occurrence of a certain event. But a difficulty arises when it is not settled whether the dower is prompt or deferred.
   
   In the case of Nasiruddin v. Amatulf [25], 1948 the Lahore High Court was determining whether the dower is prompt or deferred. They concluded that this issue should be determined based on customs of the party and usages and in the case where there is no specific usage or customs one shall be considered as deferred and other as prompt. This may sometimes differ from case to case.
   
   In another case of Beena v. B. Mohammed[26], 2015 the court held that the defendant who was the husband, he was liable to pay either at the demand, time of marriage or dissolution as it is a case of prompt dower. He is liable to pay the amount which was fixed during the time of marriage.
    
3. Quantum (Minimum & Maximum) of Mahr fixed under different Muslim Law School
   With regards to the amount of dower that a woman is entitled to receive, different jurists have different opinion. According to the Shafi and Shariya schools of thought, there is no fixed amount of sum a Muslim woman is entitled to receive. According to the jurists of the Hanafi school of thought, a Muslim woman is entitled to receive a dower that must be at least ten dirhams and in Maliki School the dower that a Muslim wife is entitled to receive, according to Maliki jurists, should not be less than three dirhams.[27]
   
   However, there is an exception for the Muslims who are extremely poor and cannot afford to pay even ten dirhams in lieu of the dower fee may teach their wives the Quran. According to many jurists, there should not be a set maximum amount of dower that a husband is required to pay in accordance with Islamic law. A man must be given the liberty to pay as much as he can depending on his affordability and financial status.
   
   There is no set amount of dower that a Muslim wife is entitled to receive, according to Quranic verse. View of several jurists is that the amount of dower that a Muslim woman is entitled to receive should be in line with the man's economic and social status.[28]Hence, Shafi School there is no fixed amount, in Shariya School there is no fixed amounts for those muslims who are poor cannot even pay 10 Dirhams, they can teach Quran instead of paying Mehar to them, in Maliki School amount fixed is 3 Dirhams and in Hanifi School the fixed amount is 10 Dirhams.
    
4. Conditions of payment of dower under different circumstances
   When the marriage is consummated but dissolved due to husband's death. When a marriage is valid, both the Muslim and the wife are entitled to the specific dower as stated in the marriage contract. If the amount is unspecified and the marriage is an irregular marriage (unlawful marriage with limited legal effect), the Muslim wife is entitled to the specified dower or the proper dower, whichever is less. In that case, the full amount of the dower will be given to her, or she will be entitled to proper dower.[29] When the marriage is consummated but dissolved by divorcea i.e. divorce given by husband.
   
   When a husband gives his wife divorce, the wife is entitled to half of the specified dower or, in the absence of a specified dower, a gift of three articles. If, however, the marriage is an irregular marriage (an unlawful marriage with limited legal effects), the Muslim wife is not entitled to any dower and when a wife gives her husband a divorce in such a situation, she is not entitled to any dower.[30]

Remedies available to Muslim women to recover he unpaid dower

1. Right to Refuse of Conjugal Rights
   According to Muslim law, if the dower is unpaid and the marriage has not yet been consummated, the wife can choose to live separately. Since an unpaid dower is a valid justification, the wife may refuse to cohabitate with her husband and refuse from having sex with him until the dower is paid. In the case of Wilayat Hussain v. Allah Rakhi[31] the court held that if the husband failed to pay Mehar to his wife and on this ground she can refuse to have sexual relationship with him.[32]
   
   Even in these situations, the husband is legally bound by law to maintain his wife. If the wife is a minor or lunatic, her parents may refuse to send her to live with her husband until the dower money is paid. In the cases of Abdul Kadir v. Salima and Nasra Begum v. Rizwan Ali[33], the court held that the wife could refuse to live with her husband until he pays the dower. Even if the husband submits a petition for the restitution of conjugal rights prior to the marriage's consummation, it will be rejected. If the wife still refuses to cohabit with her husband, then she is only entitled to a decree conditional payment on dower.
   
   In the case of Rabia Khatoon v. Mukhtar Ahmed[34], (1966), it was decided that if the suit is filed after a sexual relationship took place with the free consent, the proper decree to pass is not a decree of dismissal, but a decree for restitution, conditional on payment of prompt dower.
    
2. Right of Retaining Possession In Lieu Of Unpaid Dower
   The widow has a right of lien on the property of her husband after his death till the time the dower amount is paid to her. Regardless of any agreement between the parties, the widow gets the right to retain her property. If the woman has lawfully taken possession of her husband's property, she can retain it until the dower money is paid to her.
   
   The legal heirs of the property as well as any creditors are subject to the same privilege. Until the unpaid sum of dower to the widow is paid, no other party may benefit in any way from that property. The widow's right to keep the property does not mean that she has any other right to it.[35] She has only the right to keep possession of such property up until the dower money is given to her. Right of lien may also be exercised in divorce cases where there has been a dissolution of the marriage.
    
3. Right of Enforcement of Dower as a Debt
   After the husband's death, the widow may take legal action against the deceased's representatives to recover the unpaid amount of dower. The sum of the unpaid dower is not personally owed by the representatives of the deceased. The amount owed by the legal heirs against the estate of the deceased husband is known as the dower. However, if the husband is still alive and the marriage has been legally consummated, the wife cannot refuse to live with her husband.
   
   In certain situations, the wife has the right to file a lawsuit in court to recover the unpaid dower money.[36] The wife can realise it from her husband in the similar way as a creditor recovers the loan. In the case of Bano Begum v. Mir Aun Ali[37] the Bombay high court ruled that the widow never received any dower from her deceased husband when she got divorced. In such situation she can approach the court in order to get her unpaid dower and court is under the obligation to pass an order for the recovery of the dower.
    

Features of Right to Retention Exercised in Lieu of Dower

During the continuance of the marriage, the wife does not have any right to keep the property. The same can only be used once a marriage has been dissolved, either by divorce or death; The term "right to retain the property" refers to ownership of the possession until the Muslim wife's dower is paid. After the marriage has been dissolved, the widow must have actual possession of the husband's property.

Either a divorce or a husband's death might cause the dissolution; A right of retention is not comparable to a mortgage because the widow has no ownership in the property.[38] She just retained ownership of the property as a mortgage. The right to retain goods can be exercised without entering into any agreements because the law itself gives the widow such a right, whereas in the case of a mortgage, an agreement has been entered into by both parties;

The widow or Muslim woman has the right to keep her husband's possessions when their marriage is dissolved, but because she is not a secured creditor, this right has no effect on the property's value. When the wife is in possession of the property and the husband has mortgaged it to a third party, the mortgagee has the right to sell the property and terminate the wife's right of possession; A woman does not have a legal title to her husband's property if she has a possessory lien on it.[39]

The woman has no legal ownership to the property other than the right to retain it. The actual title to the property belongs in its legal representatives, which includes the women. The woman can use the accruing profits and rentals from her husband's property to satisfy her unpaid portion of her dower. Only her own portion of the husband's property may be sold or mortgaged by Muslim wives, and if the wife gives up custody of the property, the legal representatives may instantly reclaim control of their possession of the property.

If the alienation is overturned, the widow loses her right to possessions. Does she lose her right to the dower if she gives up possession of it? If the widow is disposed of by the husband's heirs or transferees, she can only regain ownership by filing a complaint under Section 9 of the Specific Relief Act within six months of the disposition, failing which she will forfeit her right to do so. In accordance with Article 12 of the Indian Limitation Act, she has 12 years to file a case if she is ejected by a trespasser.

In the case of Maina Bibi v. Chaudhary Vakil Ahmad[40], the trial court judge ruled that the legal representatives could only obtain possession of the property after paying the women a sum of $25.357 within a period of six months. If they were unable to do so, the court would dismiss their suit. In the same case, the Privy Council declared that Muslim law gives the widow the right to keep possession of the property up until the dower payment is paid to her.[41]

A property's widow in possession is responsible for accounting for the property. A widow who owns her husband's property is legally required to pay her husband's legal representatives any rentals and earnings she receives from that property. The widow has the right to levy interest on any unpaid dower and deduct it from her net earnings.[42] The court declared that "a widow in possession of her husband's property in lieu of dower debt is liable to account to other sharers of income from such property, in her possession" in the case of Shaikh Salma vs. Mohammad Abdul Kada[43].

Right of retention, whether it is transferable or heritable. Legal perspectives exist about the transferability and heritability of the right to retain the husband's property. According to one viewpoint, Muslim women's right to maintain their property is a personal right granted to them rather than a lien, therefore it cannot be lent or sold and cannot be transferred in the name of a widow's legal representatives after she dies.[44]

According to a different view by the Mysore High Court, the right to keep the husband's property is both inheritable and transferable because it can be acquired by the widow's legal representatives after her death. There is a case law as Ahmadv. Azizullah, in which the court held that the right of retention is an inheritable right but did not give an opinion about its transferability.[45] The Allahabad High Court shared the same decision as the Mysore High Court in one of its decisions, holding that the right to keep a husband's property is a transferable and inheritable right.

Comparison of Mehr/Dowry practice in Muslims & Hindus

There are different cultures and religions around the world, and the practise of dowry is one of them. Although the practise has different forms and different cultural and religious importance in each, dowry is particularly prevalent in Hindu and Muslim communities throughout India.

Dowry is a sum of money given by the bride's family to the groom's family at the time of marriage in Hindu tradition. The dowry is often seen as a means through which the bride's family can showcase their wealth and social standing and pay the groom's family to for the compensate for the wedding. In certain cases, the dowry must be paid in order for the marriage to proceed, and failure to pay can lead to social ostracism or even violence against the bride.

The dowry custom is different in Muslim culture. They don't recognise the notion of dowry, but at the time of marriage, the husband gives the bride a sum of money known as "Mehr." Mehr is seen as an essential part of the marriage contract and provides financial security for the bride. Mehr can be paid in the form of cash, property, or other assets, unlike dowry, which is usually given in the form of gifts or cash.

It is important to note that while the idea of Mehr is mandatory in Muslim marriages, paying dowries is not. However, the practise of dowry has extended throughout several Muslim communities in India and is frequently considered as a means of upholding social status and ensuring a good partner for the bride. In these communities, the groom's family often expects the payment of dowry, and failure to do so might result in social exclusion or even violence against the bride.

In conclusion, dowry is a widespread custom in both Hindu and Muslim groups in India, although its cultural and religious importance varies greatly depending on the community. The Muslim custom of Mehr acts as a financial security for the bride, whereas Hindus view dowry as a means of showing social and financial status. Even Nevertheless, both religions are trying to eradicate the practise of dowry because it has been linked to social issues and violence against women in both religions.

Conclusion
The researcher concludes from the current study that concept of dower holds vital importance in Muslim marriages. In Muslim marriages, the husband's custom of paying dower is still prevalent. Essentially, dower is offered in good faith for the welfare of the wives. It prevents the abuse of power to divorce her wife without a valid reason. The research also concludes that the women are entitled to some specific rights, which she can use to pursue the unpaid dower payment. The law has not been able to take a single stand on the matter, and several courts throughout the nation have stated conflicting opinions.

End-Notes:

1. Fyzee, Asaf. 'Outlines of Muhammadan Law.' Oxford university press 4th ed., 2008 pp. 69-116
2. Fyzee, Asaf. 'Outlines of Muhammadan Law.' Oxford university press 4th ed., 2008 pp. 69-116
3. Fyzee, Asaf. 'Outlines of Muhammadan Law.' Oxford university press 4th ed., 2008 pp. 69-116
4. Fyzee, Asaf. 'Outlines of Muhammadan Law.' Oxford university press 4th ed., 2008 pp. 69-116
5. Fyzee, Asaf. 'Outlines of Muhammadan Law.' Oxford university press 4th ed., 2008 pp. 69-116
6. Fyzee, Asaf. 'Outlines of Muhammadan Law.' Oxford university press 4th ed., 2008 pp. 69-116
7. Fyzee, Asaf. 'Outlines of Muhammadan Law.' Oxford university press 4th ed., 2008 pp. 69-116
8. Fyzee, Asaf. 'Outlines of Muhammadan Law.' Oxford university press 4th ed., 2008 pp. 69-116
9. Fyzee, Asaf. 'Outlines of Muhammadan Law.' Oxford university press 4th ed., 2008 pp. 69-116
10. Fyzee, Asaf. 'Outlines of Muhammadan Law.' Oxford university press 4th ed., 2008 pp. 69-116
11. Fyzee, Asaf. 'Outlines of Muhammadan Law.' Oxford university press 4th ed., 2008 pp. 69-116
12. Fyzee, Asaf. 'Outlines of Muhammadan Law.' Oxford university press 4th ed., 2008 pp. 69-116
13. Fyzee, Asaf. 'Outlines of Muhammadan Law.' Oxford university press 4th ed., 2008 pp. 69-116
14. Fyzee, Asaf. 'Outlines of Muhammadan Law.' Oxford university press 4th ed., 2008 pp. 69-116
15. Fyzee, Asaf. 'Outlines of Muhammadan Law.' Oxford university press 4th ed., 2008 pp. 69-116
16. Fyzee, Asaf. 'Outlines of Muhammadan Law.' Oxford university press 4th ed., 2008 pp. 69-116
17. Abdul Kadir v. Salim [1886] ILR 8 All 149
18. Fyzee, Asaf. 'Outlines of Muhammadan Law.' Oxford university press 4th ed., 2008 pp. 69-116
19. Fyzee, Asaf. 'Outlines of Muhammadan Law.' Oxford university press 4th ed., 2008 pp. 69-116
20. Syed Husain v. Farzand Hasan [1938] 40 BOMLR 735
21. Fyzee, Asaf. 'Outlines of Muhammadan Law.' Oxford university press 4th ed., 2008 pp. 69-116
22. Fyzee, Asaf. 'Outlines of Muhammadan Law.' Oxford university press 4th ed., 2008 pp. 69-116
23. Fyzee, Asaf. 'Outlines of Muhammadan Law.' Oxford university press 4th ed., 2008 pp. 69-116
24. Fyzee, Asaf. 'Outlines of Muhammadan Law.' Oxford university press 4th ed., 2008 pp. 69-116
25. Nasiruddin v. Amatulf AIR 1948 Lah 135 (FB).
26. Beena v. B. Mohammed, 2015 Crl. Rev. Pet. No. 92 of 2014 ()
27. Bhandari, Twinkle. 'Rights of Muslim Women in case of Unpaid Dower.' International Journal of Science and Research Vol 11 issue-5 pp- 1516-1520.
28. Bhandari, Twinkle. 'Rights of Muslim Women in case of Unpaid Dower.' International Journal of Science and Research Vol 11 issue-5 pp- 1516-1520.
29. Bhandari, Twinkle. 'Rights of Muslim Women in case of Unpaid Dower.' International Journal of Science and Research Vol 11 issue-5 pp- 1516-1520.
30. Bhandari, Twinkle. 'Rights of Muslim Women in case of Unpaid Dower.' International Journal of Science and Research Vol 11 issue-5 pp- 1516-1520.
31. Wilayat Hussain v. Allah Rakhi [1880] ILR 2 All 831
32. Bhandari, Twinkle. 'Rights of Muslim Women in case of Unpaid Dower.' International Journal of Science and Research Vol 11 issue-5 pp- 1516-1520.
33. Nasra Begum v. Rizwan Ali AIR 1980 All 118
34. Rabia Khatoon v. Mukhtar Ahmed [2005] 3 GLR 194
35. Bhandari, Twinkle. 'Rights of Muslim Women in case of Unpaid Dower.' International Journal of Science and Research Vol 11 issue-5 pp- 1516-1520.
36. Bhandari, Twinkle. 'Rights of Muslim Women in case of Unpaid Dower.' International Journal of Science and Research Vol 11 issue-5 pp- 1516-1520.
37. Bano Begum v. Mir Aun Ali [1907]9 BOMLR 188
38. Bhandari, Twinkle. 'Rights of Muslim Women in case of Unpaid Dower.' International Journal of Science and Research Vol 11 issue-5 pp- 1516-1520.
39. Bhandari, Twinkle. 'Rights of Muslim Women in case of Unpaid Dower.' International Journal of Science and Research Vol 11 issue-5 pp- 1516-1520.
40. Maina Bibi v. Chaudhary Vakil Ahmad 51 Ind Cas 242
41. Bhandari, Twinkle. 'Rights of Muslim Women in case of Unpaid Dower, International Journal of Science and Research Vol 11 issue-5 pp- 1516-1520.
42. Bhandari, Twinkle. 'Rights of Muslim Women in case of Unpaid Dower.' International Journal of Science and Research Vol 11 issue-5 pp- 1516-1520.
43. Bhandari, Twinkle. 'Rights of Muslim Women in case of Unpaid Dower.' International Journal of Science and Research Vol 11 issue-5 pp- 1516-1520.
44. Shaikh Salma vs. Mohammad Abdul Kada, AIR 1961 A.P 42
45. Bhandari, Twinkle. 'Rights of Muslim Women in case of Unpaid Dower.' International Journal of Science and Research Vol 11 issue-5 pp- 1516-1520.
46. Bhandari, Twinkle. 'Rights of Muslim Women in case of Unpaid Dower.' International Journal of Science and Research Vol 11 issue-5 pp- 1516-1520.

Cases Referred to:

• Abdul Kadir v. Salim
• Nasra Begum v. Rizwan Ali
• Rabia Khatoon v. Mukhtar Ahmed
• Maina Bibi v. Chaudhary Vakil Ahmad
• Shaikh Salma vs. Mohammad Abdul Kada
• Ahmad v. Azizullah
• Bano Begum v. Mir Aun Ali
• Nasiruddin v. Amatul
• Beena v. B. Mohammed
• Wilayat Hussain v. Allah Rakhi