facebok style

Gokula Ranjana Pr. Vs. FDG

  An analysis of the paper “Some Evidence Regarding Education and Guruship for Vaishnavis”

by Goloka-ranjana Dasa
Introduction

Among scholars, the position of women in the Vedic culture is a cause for controversy and debate because of different, sometimes contradictory statements found in Vedic literature. As we know from the Mahābhārata, nāsau ṛṣir yasya matam na bhinnam—sages have their own opinions and often contradict other sages. Thus the only path to the truth is mahājano yena gataḥ sa panthaḥ—the path traversed by great authorities. That is why we would like to analyze through the teachings of Śrīla Prabhupāda and our previous ācāryas some of the different quotes and arguments presented in the paper “Some Evidence Regarding Education and Guruship for Vaishnavis,” authored by Bhaktarupa Prabhu and Madhavananda Prabhu.* Since their paper substantially relies on the authority of lesser-known scriptures and commentators, we will examine their evidence within the broader context of the sources they quote. That is, we want to determine whether their translations of these scriptures and commentators can be legitimately inferred from the context of these same sources. Also, the wide use of exotic sources by the authors raises the question as to whether they are introducing opposing scriptures. “One should not introduce any opposing scripture” (Nectar of Devotion, Ch. 8, “Offenses to be avoided”). We will therefore also weigh the authority of these statements within our Gauḍīya-Vaiṣṇava tradition. As fidelity to the conclusions of our sampradāya is essential for the propagation of the Krishna consciousness movement, this is a serious issue that must be deeply deliberated upon. That is why we decided to produce this analysis.
The authors of the paper have done otherwise wonderful service to the society of devotees. They are sincere and have given their lives for the service of Śrīla Prabhupāda. And although it is certain their intent is not malicious, it nonetheless seems that in their research they sometimes relied on someone's incomplete research, since some of the arguments are extrapolated, misleading, taken out of context or even fallacious. Falling to their feet, we heartily apologize before them for our impudence in trying to analyze their arguments. We sincerely hope and pray to them and to all the devotees that they will not take this friendly analysis as a personal attack and will not be offended by our presentation. The reason for this analysis was our apprehension that someone in the position of authority or leadership may base their decisions on such in many ways imbalanced evidence.
All the quotes from the paper will be marked by the borders on both sides:
The present paper is primarily an exploration into śāstra regarding the roles and responsibilities of vaiṣṇavīs.
However, their paper unfortunately does not give a balanced, broad view of the roles and responsibilities of vaiṣṇavīs, but what seems a partial view, not considering the vast multitude of other explicit and implicit examples and direct instructions from the śāstra.
Of course there have been several examples of women philosophers (the famous examples of them are Maitreyī and Gargī from the Bṛhad-araṇyaka-upaniṣad) or even dīkṣā-gurus (like Jāhnavā Ṭhākuraṇī or Hemalatā Ṭhākuraṇī) but still, their number is much less than the male representatives and we are left with no explanation as to why it is so.
* 11 Jan. 2013, Dandavats, 31 Dec. 2014 http://www.dandavats.com/?p=11189&paged=3
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WOMEN IN THE VEDAS
The Vedic age can be described correctly only in the language of the Vedas and its supporting literature — the various brāhmaṇas, upaniṣads, etc. The following passages offer an insight into the position and rights of women in the Vedic age.
CREATED AS EQUAL HALVES
The Bṛhad-āraṇyaka-upaniṣad (1.4.3) contains the following passage —
sa dvitīyam aicchat. sa haitāvān āsa yathā strīpumāṁsau sampariṣvaktau. sa imam evātmānaṁ dvedhāpātayat. tataḥ patiś ca patnī cābhavatām. tasmād idam ardhabṛgalam iva sva iti ha smāha yājñavalkyaḥ.
He (the Supreme Lord) desired a partner. Assuming a form as great as the form of a man and woman combined, he divided this great form of himself and thus two equal parts fell, from which husbands and wives, respectively, were produced. Therefore, Yājñavalkya said that both of us are like two equal halves of a shell.
First of all, it should be noted that there is no such word as “equal” in the original Sanskrit quote from Bṛhad-āraṇyaka-upaniṣad, 1.4.3, which the paper takes liberty to use twice. It says only that “two parts fell” (dvedhāpātayat) and “two halves similar to a pea” (ardha-bṛgalam). If someone objects that ardha means precisely an equal half because a half cannot be unequal—that is not so, because we also see the word ardha in the famous logic of half-hen or “ardha-kukkuṭī-nyāya”, where the upper part of the hen's body was cut to save only the lower part which produced eggs. Obviously they were the halves (ardhas), but not equal.
Second, the text preceding this clearly states that the original person was male - ātmaivedam agra āsīt puruṣavidhaḥ (1.4.1). [emphasis added]
Third, it is the woman who “fills the space” lacking in a man at the time of marriage and not vice versa - tasmād ayam ākāśaḥ striyā pūryata eva (continuation of the same passage from the Bṛhad-āraṇyaka-upaniṣad, 1.4.3).
If they were equals in all respect, then how do we explain this statement from the 6th chapter of Bṛhad-āraṇyaka-upaniṣad:
śrīr ha vā eṣā strīṇāṃ yan malodvāsāḥ. tasmān malodvāsasaṃ yaśasvinīm abhikramyopamantrayeta (6.4.6)
sā ced asmai na dadyāt kāmam enām avakriṇīyāt. sā ced asmai naiva dadyāt kāmam enāṃ yaṣṭyā vā pāṇinā vopahatyātikrāmet. indriyena te yaśasā yaśa ādada iti. ayaśā eva bhavati (6.4.7)
Translation (by P.Olivelle, slightly edited): “Surely, a woman who has changed her clothes at the end of her menstrual period is the most auspicious of women. When she has changed her clothes at the end of her menstrual period, therefore, one should approach that splendid woman and invite her to have sex [as is clear from the next verses the sex is for procreation]. Should she refuse to consent, he should bribe her. If she still refuses, he should beat her with a stick or with his hand and overpower her, saying: "I take away the splendor from you with my virility and splendor." And she is sure to become bereft of splendor. If, on the other hand, she accedes to his wish, he should say: "I confer splendor on you with my virility
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and splendor." And then they are both sure to become full of splendor.”[1] (According to the Mahābhārata and other scriptures, if the wife refuses when her husband approaches her with a desire to have a child, she commits a sin).
Even in our Gauḍīya-vaiṣṇava tradition it is an accepted fact that the wife (or more generally a woman) is not equal to her husband. This is directly described in one of the most elevated scriptures, Śrī Caitanya-caritāmṛta (Ādi-līlā, 10.137 and Antya-līlā, 2.104-106), where Mādhavī Devī, although being a great vaiṣṇavī, is still described as “ardha-jana” (half a person) while her brother, Śikhi Māhiti is described as a full, third person among the three and a half closest associates of Mahāprabhu. Śrīla Prabhupāda comments: “The three were Svarūpa Gosāñi, Śrī Rāmānanda Rāya and Śikhi Māhiti, and Śikhi Māhiti’s sister, Mādhavīdevī, being a woman, was considered the half. Thus it is known that Śrī Caitanya Mahāprabhu had three and a half confidential devotees.” (Caitanya-caritāmṛta, Ādi-līlā, 10.137, purport)
This is again corroborated by Śrīla Bhaktisiddhānta Sarasvatī Ṭhākura in his Anubhāṣya commentary to Caitanya-caritāmṛta, Ādi-līlā, 11.26, where he gives a list of descendants of Gaurīdāsa Paṇḍita. In that list Rāiyā Kṛṣṇadāsa is the 22nd and Annapūrṇā, being a woman, is similarly enumerated as 22½. Śrīla Prabhupāda also follows his Guru Mahārāja's numbering in his BBT edition of Śrī Caitanya-caritāmṛta.
EQUAL RIGHTS TO EDUCATION AND CELIBACY
Direct evidence supporting the equal right to education is found in the Atharva-veda (11.5.18) as follows,
brahmacaryeṇa kanyā yuvānaṁ vindate patim
Through brahmacarya a girl attains a suitable husband.
So what is this brahmacarya? Sāyaṇa, the most prominent commentator on all the four Vedas, comments on the above Atharva-veda section:
brahmacaryeṇa brahma vedaḥ tad-adhyayanārtham-ācaryam
The word brahmacaryeṇa means “by all efforts employed to study the Vedas in order to know Brahman”.
The commentary here is mixed with the commentary to the previous verse (11.5.17) and incorrectly translated - there is no such part as “in order to know Brahman”, the word “brahma” means “the Vedas”, says Sāyaṇa[2] (just as in the SB1.1.2—tene brahma hṛdā ya ādi-kavaye... - “He imparted the Vedic knowledge unto the heart of Brahmā (ādi-kavi)”).
The verse 11.5.17 with the commentary is as follows:
brahmacaryeṇa tapasā rājā rāṣṭram vi rakṣati
ācāryo brahmacaryeṇa brahmacāriṇam icchate
“Through brahmacarya the king particularly protects his kingdom. Through brahmacarya the teacher desires [to have] a brahmacari[-disciple].”
Sāyaṇa-bhāṣya: brahma vedaḥ, tad-adhyayanārtham ācaryam ācaraṇīyaṁ samid-ādhāna-
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bhaikṣacaryordhvaretaskatvādikaṁ brahmacāribhir anuṣṭhīyamānaṁ karma brahmacaryam.
Translation of the commentary: “Brahma means ‘the Vedas’, the activity to be performed by the brahmacaris in order to study them, such as igniting the firewood, begging alms, lifting up the semen etc. is called brahmacarya.”
This part of the Atharva-veda is indeed very interesting, however if we are to accept that it establishes women's equal rights to education we will have to accept an exactly equal right of a king, an ox, a horse and the demigods who are similarly described in the same section:
anaḍvān brahmacaryeṇāśvo ghāsam jigīrṣati (11.5.18)
“Through brahmacarya the ox and the horse desire to eat grass”
brahmacaryeṇa tapasā devā mṛtyum apāghnata
indro ha brahmacaryeṇa devebhyaḥ svar ābharat (11.5.19)
“Through brahmacarya and austerity the demigods defeated death. Through brahmacarya Indra brought heaven for the demigods.”
The Śrīmad-bhāgavatam speaks of two ladies attaining to complete Vedic knowledge:
tebhyo dadhāra kanye dve vayunāṁ dhāriṇīṁ svadhā
ubhe te brahma-vādinyau jñāna-vijñāna-pārage
Svadhā, who was offered to the Pitās, begot two daughters named Vayunā and Dhāriṇī, both of whom were impersonalists and were expert in transcendental and Vedic knowledge. (4.1.64)
Another example of a lady who attained to complete Vedic knowledge is Devahūti, who is also called brahmavādinī in the Śrīmad-bhāgavatam (3.33.12):
maitreya uvāca
iti pradarśya bhagavān satīṁ tām ātmano gatim
sva-mātrā brahmavādinyā kapilo’numato yayau
“Śrī Maitreya said: The Supreme Personality of Godhead Kapila, after instructing His beloved mother, took permission from her and left His home, His mission having been fulfilled.”
However, in the purport to the next verse (3.33.13) Śrīla Prabhupāda clearly states that in spite of being a self-realized knower of the Absolute Truth (brahmavādinī) a woman still should be dependent, stay at home and practice bhakti-yoga:
sā cāpi tanayoktena yogādeśena yoga-yuk
tasminn āśrama āpīḍe sarasvatyāḥ samāhitā
“As instructed by her son, Devahūti also began to practice bhakti-yoga in that very āśrama. She practiced samādhi in the house of Kardama Muni, which was so beautifully decorated with flowers that it was considered the flower crown of the River Sarasvatī.”
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Purport: “Devahūti did not leave her house, because it is never recommended for a woman to leave her home. She is dependent. The very example of Devahūti was that when she was not married, she was under the care of her father, Svāyambhuva Manu, and then Svāyambhuva Manu gave her to Kardama Muni in charity. She was under the care of her husband in her youth, and then her son, Kapila Muni, was born. As soon as her son grew up, her husband left home, and similarly the son, after discharging His duty towards His mother, also left. She could also have left home, but she did not. Rather, she remained at home and began to practice bhakti-yoga as it was instructed by her great son, Kapila Muni, and because of her practice of bhakti-yoga, the entire home became just like a flower crown on the River Sarasvatī.” (SB3.33.13)
SOME HYMNS RESERVED FOR THEM
There are many hymns in the Ṛg-veda that are reserved for recitation only by women. An example (Ṛg-veda 10.159.1-2) speaks about a woman‘s qualification to speak on transcendental topics:
ud asau sūryo agād ud ayaṁ māmako bhagaḥ
ahaṁ tad vidvalā patim abhy asākṣi viṣāsahiḥ
ahaṁ ketur ahaṁ mūrdhāhamugrā vivācanī
mamed anu kratuṁ patiḥ sehānāyā upācaret
Let my good fortune rise with the rising sun. May I attain my husband, defeat my enemies, and may I always be very tolerant. May I be an excellent knower of the Vedas, and a powerful speaker on the same. May my husband always be pleasing and behave tolerantly towards me.
Actually, there is nothing transcendental in this hymn. It would be interesting to know on what authority the authors gave such a highly esoteric translation. Until we know what ācārya gave such an interpretation of the verse, we would rather stick to the traditional meaning. It is a hymn where the speaker (Śacī Paulomī, Indra's consort) prays for destruction of her rivals (sapatnī).
In the Sanskrit text itself, there are no such things there as “excellent knower of the Vedas” or “a powerful speaker on the same.” Sāyaṇa[3] explains the word “ketuḥ”, which the authors chose to translate very specifically as “the excellent knower of the Vedas”, in more general words as “sarvasya jñātrī” - “knower of everything.” “Aham mūrdhā” means “may I become prominent [as a head]” and “ugra vivācanī” means “may I evoke good speech - even if my husband is in an angry mood, I will always make him speak pleasant words.”
For comparison, here is the English translation by Ralph T. H. Griffith on the basis of Sāyaṇa-bhāṣya[4]:
Sun hath mounted up, and this my happy fate hate mounted high.
I knowing this, as conqueror have won my husband for mine own.
I am the banner and the head, a mighty arbitress am I:
I am victorious, and my Lord shall be submissive to my will.
Even if we accept that women sometimes might have studied some parts of the Vedas, it does not establish this right for each and every part of the Vedas—since it would contradict the direct statement from the crest-jewel of all authorities, Śrīmad-bhāgavatam (1.4.25)—strī-śūdra-dvijabandhūnāṁ trayī na śruti-
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gocarā—“The less intelligent classes of men, namely women, śūdras and unqualified sons of the higher castes, are devoid of necessary qualifications to understand the purpose of the transcendental Vedas.” (from Śrīla Prabhupāda's purport to SB1.4.25). The possible reconciliation of these two contradictions may be analogous to the well-known example of the Rathakāras, discussed in the Mīmāṁsā-sūtra (6.1.44-50) and used by Śrīla Baladeva Vidyābhūṣaṇa in his Siddhānta-darpaṇa (2.3) to show that even śūdras are sometimes eligible to study the Vedas and recite the appropriate mantras, but only those “some” portions of the Vedas that are directly prescribed for them to study. Or a similar logic given by Jaimini in his Mīmāṁsā-sūtra (6.1.24) can be applied here too. We will discuss that later.
ELIGIBLE TO RECEIVE THE GAYATRI AND THE SACRED THREAD
The Yama-smṛti specifies the right of women to study Vedas and receive the thread,
purā-kalpe tu nārīṇāṁ mauñjī-bandhanam-iṣyate
adhyāpanaṁ ca vedānāṁ sāvitrī vacanaṁ tathā
Previously women were initiated with Brahmin threads and would teach the Vedas and acquire knowledge of the Gāyatrī.
Thus, there are quite a few places in the Vedas where women have been encouraged to teach and perform all kinds of sacrifices, including initiations.
The verse the authors cite does not mention a Brahmin thread - “mauñjī” is a belt, made of sacred grass (muñja) which is tied (bandhanam) around the waist at the time of upanayana. (See, for example, Manu-saṁhitā, 2.42-43,169-171).
This quote from Yama-smṛti is incomplete, it goes on as follows[5]:
pitā pitṛvyo bhrātā vā nainām adhyāpayet paraḥ
sva-gṛhe caiva kanyāyā bhaikṣa-caryā vidhīyate
varjayed ajinaṁ cīraṁ jaṭādhāraṇam eva ca
Translation (by Prof. V.P. Kane):
“In former ages, tying of the girdle of muñja (i.e. upanayana) was desired in the case of maidens, they were taught the Vedas and made to recite the Savitrī (the sacred Gāyatrī verse). Either their father, uncle or brother taught them and not a stranger and begging was prescribed for a maiden in the house itself and she was not to wear deer-skin or bark garment and was not to have matted hair.” (History of Dharma-sastra, in 5 Volumes, 1930-1962, Vol.2, p.295—from now on all the references to Prof. Kane or his History of Dharma-sastra are made to this edition).
Since the girl was restricted (her initiation was only to her close relatives, and she had to beg alms only from her own house), it is unfeasible that she taught the Vedas to others. Thus the phrase “[women] would teach the Vedas” seems extrapolated. Nevertheless, the authors give a reading of the text that defies its very context: “Thus, there are quite a few places in the Vedas where women have been encouraged to teach and perform all kinds of sacrifices, including initiations.” However, it is clear that they have given an unwarranted extrapolation, since the text itself gives no evidence of actual “encouragement for performance of all kinds of sacrifices” what to speak of giving initiation.
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This quote from the Yama-smṛti is usually accompanied by the quote from the Hārīta-smṛti that is also quoted in the paper under the title “TWO TYPES OF LADIES”. We will discuss both of them here:
The Hārita-smṛti, which is much older and broader in its outlook than the current edition of the Manu-smṛti, speaks about two types of women as follows,
dvividhāḥ striyaḥ. brahma-vādinyaḥ sadyo-vadhvaś ca. tatra brahma-vādinīnām upanayanam agnīndhanaṁ vedādhyayanaṁ sva-gṛhe-ca bhikṣācaryā iti. sadyo-vadhūnāṁ tūpasthite vivāhe kathañcid- upanayana-mātraṁ kṛtvā vivāhaḥ kāryaḥ (21.23)
There are two types of ladies — the brahmavādinī, who doesn‘t desire to marry, and the sadyo- vadhū, who wishes to marry. For the brahmavādinī there is provision for receiving the sacred thread, conducting the fire sacrifice, studying the Vedas, and begging alms at her own home.
The sadyovadhū at the time of marriage should only be invested with the sacred thread and then married.”
Again, the text does not mention “the sacred thread” but only the “upanayana”, which for boys was certainly performed with the investiture of the sacred thread but, as we have seen above, there are several points that make it quite different from the boys' upanayana, namely:

Only a close relative could perform the upanayana for girls and not a stranger;

A girl could not go out of her house to beg alms (as boys did)

She was not to wear deer-skin or bark garment and was not to have matted hair (as was the case with boys).

So, we can safely doubt the extrapolated assumption that they were “invested with the sacred thread.”
We should also say that the same Vīramitrodaya (where these quotes from the Yama- and Hārīta-smṛtis appear) concludes the discussion about “Initiation of women” by saying:
purā-kalpa iti vacanān nāsmin kalpa iti gamyate. ata eva manuḥ:
vaivāhiko vidhiḥ strīṇāṁ saṁskāro vaidikaḥ smṛtaḥ
patisevā gurau vāso gṛhārtho'gniparikriyā
“From the words purā-kalpe we can understand that it is not for this age. Therefore Manu has said: “The marriage ceremony is stated to be the Vedic sacrament for women (and to be equal to the initiation), serving the husband (equivalent to) the residence in (the house of the) teacher, and the household duties (the same) as the (daily) worship of the sacred fire.’” [this verse appear in the Manu-saṁhitā, 2.67].
These two quotes from Hārīta and Yama smṛtis are interesting in several ways. First of all, they are not found in any of the present editions or editions of these two smṛtis. They are known only from the medieval smṛti digests that include these quotations, such as Vīramitrodaya (which was used by the authors, it was written ca. 1610-1620 AD), Smṛti-candrikā (ca. 1150-1225 AD) and also Nirṇaya-sindhu (1612 AD). All of them agree that the words purā kalpe refer to the previous ages and not applicable now.
Smṛti-candrikā[6] adds:
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ādi-purāṇe 'pi -
yas tu kārta-yugo dharmo na kartavyaḥ kalau yuge |
pāpa-prasaktās tu yataḥ kalau nāryo-narās tathā ||
“In the Ādi-purāṇa it is said: “The dharma for Satya-yuga is not to be performed in Kali-yuga. Otherwise men and women in Kali-yuga will become strongly attached to sin.””
These two quotes from the Yama and Hārīta smṛtis have been of the favorite quotes of those who wish propagate a Hindu version of equal rights movement. Some of them go so far as to say that there were equal rights for women and men in everything and then greedy and proud priests edited the old scriptures and wrote their own to denigrate women. No need to mention, but we as Śrīla Prabhupāda's followers cannot subscribe to such views.
And finally, this verse speaks about “purā-kalpa” – the bygone age, not the present age. It implies that such rules for “equal rights” although might have been in practice in the previous ages, may not be applicable in the present age.
anye kṛta-yuge dharmās tretāyāṁ dvāpare 'pare
anye kali-yuge nṝṇāṁ yuga-rāsānurūpataḥ
One set of duties (is prescribed) for men in the Krita age, different ones in the Treta and in the Dvapara, and (again) another (set) in the Kali, in a proportion as (those) ages decrease in length. (Manu-smṛti, 1.85, the same verse also appears in the Parāśara-smṛti, 1.22).
Here are some examples of things that were prevalent in the human society in the previous ages but now are absent or even sinful:

The famous ancient Vedic authority Āpastamba, who is also mentioned in the paper we are discussing, says that in the previous ages demigods lived together with humans on this planet: saha deva manuṣyā asmil loke purā babhūvuḥ (Āpastamba-dharma-sūtra, 2.7.16.1)[7]


Mahābhārata says that in the previous ages women were not restricted and there was no marriage as we know it now:

anāvṛtāḥ kila purā striya āsan varānane
kāma-cāra-vihāriṇyaḥ svatantrāś cārulocane
tāsāṁ vyuccaramāṇānāṁ kaumārāt subhage patīn
nādharmo 'bhūd varārohe sa hi dharmaḥ purābhavat (Ādi-parva, 113.4-5)[8]
“Long ago women were not at all restricted, O lovely one. Women were self-reliant in those remote times and could go where they liked and enjoy in their own way. From childhood, fine lady, they were not faithful to their husbands, and yet their behavior was not irreligious, for that was the religious principle of those former days.”
No need to cite many other examples, but if we are not satisfied with whatever direction Śrīla Prabhupāda and previous ācāryas have given us, here is what the traditional ancient Vedic scholar Āpastamba has to say in this regard in his Dharma-sūtra (he explains that the rules that contradict dharma that were once in vogue, are not applicable in the Kali-yuga):
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dṛṣṭo dharma-vyatikramaḥ sāhasaṃ ca pūrveṣām teṣāṃ tejo-viśeṣeṇa pratyavāyo na vidyate tad anvīkṣya prayuñjānaḥ sīdaty avaraḥ[9]
“Transgression of the law and violence are found amongst the ancient (sages). They committed no sin on account of the greatness of their lustre. A man of later times who seeing their (deeds) follows them, falls.” (Āpastamba-dharma-sūtra, 2.6.13.7)[10].
And lastly, although the Hārīta-smṛti speaks about performing upanayana for women, interestingly we can hardly think of any example of this from the śāstra.
JAIMINI AND AITISAYANA
This is perhaps the most interesting part of the paper.
Jaimini is the renowned composer of the literature known as Pūrva-mīmāṁsā sūtras. According to the Śrīmad-bhāgavatam (1.4.21), he is the professor of the Sāma-veda and the direct disciple of Vyasadeva.
Jaimini‘s Pūrva-mīmāṁsā sūtras have been referred to by many ācāryas in their works, e.g. Srila Jiva Goswami in his Kṛṣṇa-sandarbha and Srila Baladeva Vidyabhushan in his Govinda-bhāṣya. Both these ācāryas quote Pūrva-mīmāṁsā sūtras as a valid and acceptable authority.
As Jaimini was compiling the Pūrva-mīmāṁsā sūtras, he wished to tackle the case of equal rights for women in all sacrifices (including dīkṣā). He was well aware of the school of a certain sage named Aitisayana, who had declared that all these sacrifices were only for the higher three classes and not for women and śūdras. Jaimini discussed this issue in the first chapter of the sixth part of his Pūrva-mīmāṁsā sūtras. The famous Vedic commentator Shabara-swami commented on these sūtras.
As we will see now, the authors’ claim that Jaimini “wished to tackle the case of equal rights” is not at all true. But before that, some remarks:

The last phrase “including dīkṣā” is again an extrapolation.

”The famous Vedic commentator Shabara-swami commented on these sūtras.” Śabarasvāmī however wasn't a Vedic commentator per se, in fact there is no other known work of Śabarasvāmī except for his commentary on Jaimini's Mīmāṃsā-sūtras.

“We are reproducing here the entire section along with the commentary of Shabara-swami.”
It is both unfortunate and ironic that the authors did not reproduce the entire section. Perhaps relying on someone's unfinished work, they also left the discussion unfinished on the point that seems to suit the purpose of such a paper. The discussion, in fact, continues and we will reproduce the lengthy but necessary section from that part of the Mīmāṁsā-sūtras[11] after analyzing the following quote from the paper:
The entire discussion revolves around the word svarga-kāmaḥ in the following aphorism in the Śruti — 
darśa-pūrṇa-māsābhyāṁ svarga-kāmo yajeta (Āpastambha Śrauta Sūtra 3.9.4)
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One who desires heaven should perform the Darśa and Pūrṇa-māsa sacrifices.
Jaimini in the Pūrva-mīmāṁsā sūtras (6.1.3.6) presents the view of the opposite party (pūrva-pakṣa) first,
liṅga-viśeṣa-nirdeśāt puṁ-yuktam-aitiśāyanaḥ (Sūtra 6)
The Sage Aitisayana says that since the gender used in the aphorism is masculine (svarga-kāmaḥ), therefore only males are eligible.
Commentary: darśa-pūrṇa-māsābhyāṁ svarga-kāmo yajetetyevam-ādi samāmnāyate. tatra sandehaḥ. kiṁ svarga-kāmaṁ pumāṁsam-adhikṛtya yajetety-eṣa śabda uccaritaḥ? atha vā’niyamaḥ striyaṁ pumāṁsaṁ ca? iti. kiṁ prāptam? puṁ-liṅgam-adhikṛtaṁ mene aitiśāyanaḥ. kutaḥ? Liṅga-viśeṣa-nirdeśāt. puṁ-liṅgena viśeṣeṇa nirdeśo bhavati, svarga-kāmo yajeteti. tasmāt pumān-ukto yajeteti, na strī.
Translation of Commentary: The aphorism One who desires heaven should perform the Darśa and Pūrṇa-māsa sacrifices‘ is seen in the Vedas. In that there is a doubt. Is the aphorism recited keeping in mind only a male, or both male and female? The sage Aitisayana says that only males are eligible. Why? It is because the masculine gender has been specified in the word svarga-kāmaḥ in the aphorism. This word refers to a man, and therefore only men are allowed, and not women.
Jaimini then gives his conclusion:
jātiṁ tu bādarāyaṇo ’viśeṣāt tasmāt stry api pratīyeta jāty arthasyāviśiṣṭatvāt (Sūtra 8)
Vyasa, however, says that both ladies and men belonging to the upper three classes are fit for all sacrifices, as there is no distinction of class between males and females in the word svarga-kāmaḥ.
Commentary: tu-śabdaḥ pakṣaṁ vyāvartayati. naitadasti puṁso ’dhikāra iti. jātiṁ tu bādarāyaṇo ’dhikṛtāṁ manyate sma āha. kim-ayaṁ svarga-kāma iti jāti-śabdaḥ samadhigataḥ? netyāha. kathaṁ tarhi? yaugikaḥ, svargecchā-yogena vartate. kena tarhi śabdena jātir-uktā yā adhikṛteti gamyate. nava ca vayaṁ brūmo jātivacana iha śabdo ’dhikāraka iti. kiṁ tarhi? Svarga-kāma śabdenobhāva ’pi strī-puṁsāvadhi kriyate iti. ato na vilakṣitaṁ puṁ-liṅgaṁ iti. kutah? aviśeṣāt. na hi śaknoty-eṣā vibhaktiḥ svarga-kāmaṁ liṅgena viśiṣṭum. katham? lakṣaṇatvena śravaṇāt. svarge kāmo yasya tam eva lakṣayati śabdaḥ. tena lakṣaṇenādhikṛto yajeteti śabdena ucyate. tatra lakṣaṇam-aviśiṣṭaṁ striyāṁ puṁsi ca. Tasmāc- chabdenobhāva ’pi strī-puṁsāv-adhikṛtāv-iti gamyate. tatra kenādhikāraḥ striyā nivartyate? vibhaktyā iti cet. Tan-na. kasmāt? Puṁ-vacanatvāt. strī-nivṛttāv-aśaktiḥ. puṁso vibhaktyā punar-vacanam-anarthakam- iti ced na. ānarthakyo ’pi strī-nivṛtter-abhāvaḥ. parisaṅkhyāyāṁ svārtha-hāniḥ. parārtha-kalpanā prāpta- bādhaś ca. na cānarthakyaṁ. nirdeśārthatvāt. tasmāt stry api pratīyeta jāty arthasyāviśiṣṭatvāt.
Translation of Commentary: By the word 'tu‘ in this sūtra, the pūrva-pakṣa is refuted. It is not that only males have the right. Those belonging to the upper three classes, whether men or women, are bonafide, as said by Vyasadeva. A question is to be asked here. Is the word 'svarga-kāmaḥ‘ to be considered as a word which defines a group or as a word which points to a single person? The other party says, It cannot point to a group, because the way in which it is grammatically formed points only to a single person, and that also a male.
However, we (the uttara-pakṣa) say that the word 'svarga-kāmaḥ‘ cannot refer only to a male.
Why? Because of its non-speciality. The word cannot be restricted only to the male species because
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* In sūtras 6.1.10-12 pūrva-pakṣa continues by saying that a sacrifice can be performed only by a person possessing property (dravyavattvāt), but since women do not possess any property and are themselves the property of father or husband (e.g. according to the Manu-saṁhitā (8.416): bhāryā dāsaś ca putraś ca nirdhanāḥ sarva eva te. yat te samadhigacchanti, yasya te tasya tad dhanam - “A wife, a son, and a slave, these three are declared to have no property; the wealth which they earn is (acquired) for him to whom they belong.”), they cannot perform sacrifices. It is interesting to note Śabarasvāmī's commentary to the sūtras 13 and 14 which give the answer to pūrva-pakṣa - being faithful to karma-mīmāṃsā tradition he urges to reject smṛti if it contradicts śruti:
yadi smṛtim anurudhyamānā paravaśā nirdhanā ca syāt, yajetety ukte sati na yajeta. tatra smṛtyā śrutir bādhyeta. na caitan nyāyyam. tasmāt phalārthinī satī smṛtim apramāṇīkṛtya dravyaṃ parigṛhṇīyād yajeta ceti.
Translation of the commentary (slightly edited translation by G.N. Jha)“If smṛti states that a woman should be without property, but śruti instructs her to perform a sacrifice (yajeta) if she has a desire for heaven, then if she follows the smṛti, remains without property and does not perform sacrifices, she commits a mistake by overruling śruti with smṛti, which is inappropriate. Therefore if she desires the fruits, she should disregard the smṛti as unauthoritative, obtain the necessary property and perform the sacrifice.”
it emphasizes eligibility over gender. The emphasis is on the fact that “One who desires heaven should perform sacrifices.” The rightful performers of the sacrifice are indicated by the word 'yajet‘. If it is said that the word 'svarga-kāmaḥ‘ is of masculine gender by rules of grammar, then we (the uttara-pakṣa) say that it is not so, for assuming that only males are indicated will lead to the following problem:
The purpose of the word svarga-kāmaḥ is to state that whosoever desires to go to heaven should perform the sacrifices. Since it is a well-observed fact that even women desire heaven, if the purpose of the original aphorism was to state that only men should perform the sacrifices then the language would have had to include specific wording to state that it did not apply to women.
Therefore, women are also included in the three higher varṇas that can perform sacrifices.
However, this translation of the commentary to the sūtra 6.1.8 is not fully accurate.
The question is from the pūrva-pakṣa:
- Is the word svarga-kāmaḥ that is denoting the whole genus (jāti)?
- No.
- Then what is it?
- The word svarga-kāmaḥ should be taken in its etymological meaning (yaugikaḥ) as “those who have the desire for svarga.”
- Then by which word is the [entitled] genus denoted?
- We do not say that there is a word denoting a genus, but by the word “svarga-kāma” both men and women are entitled and the masculine gender is not essential here.”
And the authors conclude:
“Thus, in the opinion of Vyasadeva, even women are eligible to perform all sacrifices. ”
This is, however, completely misleading and the discussion ends here for some unknown reason (perhaps the authors inadvertently used somebody's biased work, for it is unimaginable that they deliberately ended the discussion here). But in the Mīmāṃsā-sūtras Jaimini goes on to give the complete siddhānta on this issue. In the next, 4th adhikaraṇa starting with sūtra 17 he discusses the respective roles of a man and woman in the performance of sacrifices*. There Jaimini and his commentator Śabarasvāmī clearly state
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The question whether a wife posseses property or not (strīdhana) is a cause for debate among dharma-śāstra experts. At least for Pūrva-mīmāṁsā, in sūtra 16 Jaimini clearly says that there is a text that establishes that women have property and Śabarasvāmī cites interesting verse (which is a paraphrase of the śruti verse from Taittirīya-saṁhitā, 6.2.1.1) - patnī vai pāriṇayyasyeṣṭe patyaiva gatam anumataṃ kriyate - “The wife is the mistress over the household property and she acts according to the wishes of her husband.” So the wife does have property, but that property is not independent from her husband and her household.
that this injunction to perform a sacrifice does not give men and women equal right in it because they themselves are not equal. Here is the sequence:
In sūtra 17 Jaimini states that husband and wife should perform sacrifice together as a joint effort:
svavatos tu vacanād aikakarmyaṃ syāt
“Although they both posses property their action should be one [joint] because of the statement to that effect.”
Commentary: svavantāv ubhāv api daṃpatī ity evaṃ tāvat sthitam. tatra saṃdehaḥ, kiṃ pṛthak patnī yajeta, pṛthag yajamānaḥ, uta saṃbhūya yajeyātām iti. kiṃ prāptam? pṛthaktvena. kutaḥ? ekavacanasya vivakṣitatvāt. upādeyatvena kartā yajeteti śrūyate. tasmād ekavacanaṃ vivakṣyate, yathā na dvau puruṣau saṃbhūya yajeyātām, tathātrāpi draṣṭavyam.
Translation: “It has been settled that both husband and wife possess property. The doubts that arises now is ‘Should the wife perform the sacrifice separately from the sacrificer or should they perform sacrifice together?’
[Pūrva-pakṣa]: They should perform the sacrifice separately.
- Why?
- Because singular number was expressed regarding the performer - 'yajeta' - “he should perform sacrifice.” Therefore singular number was expressed and just as two men cannot perform the sacrifice, our situation should be seen similarly.”
[Siddhānta]: evaṃ prāpte brūmaḥ, svavatos tu vacanād aikakarmyaṃ syāt, vacanāt tayoḥ sahakriyā. evaṃ hi smaranti “dharme cārthe ca kāme ca nāticaritavyeti”, tathā “sahadharmaś caritavyaḥ sahāpatyam utpādayitavyam” iti.
“To this we reply: Although they both possess property they should perform the sacrifice together because of the statement to that effect, that establishes their joint effort—From the smṛti: “In the matters relating to dharma, artha and kāma she should not be ignored” and “The dharma should be performed together and the children should be begotten together.”
ucyate, smṛtivacanena na śrutivacanaṃ yuktaṃ bādhitum. neti brūmaḥ, iha kiṃcit karma strīpuṃsakartṛkam eva, yathā darśapūrṇamāsau jyotiṣṭoma iti, yatra patnyavekṣitena yajamānāvekṣitena cājyena homa ucyate, tatrānyatarābhāve vaiguṇyam.
“But it is not proper to reject statement of śruti in favor of the smṛti”.
To this we reply: No, there is no problem here. There are some sacrifices that must be performed by the man and the woman together, like Darśa-pūrṇamāsa or Jyotiṣṭoma during which one should
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offer oblations of ghee examined by both the wife and the sacrificer (yajamāna). If the either of them is absent—the sacrifice will be defective.”
Having seen that Darśa-pūrṇamāsa sacrifice is to be performed by husband and wife together (and in the absence of either the ritual will be defective) we can doubt the etymology of the name “Paurṇamāsī” given by the authors: “Ladies who performed these sacrifices are thus rightfully known as 'Paurṇa-māsī'. At best, Paurṇamāsī is not that woman who performed the pūrṇamāsa sacrifice (by herself) but who helped her husband, the officiating priest (yajamāna), in such sacrifice. But even then, why only Pūrṇamāsa, which is only one half of the full darśa-pūrṇamāsa sacrifice, why don't we hear about a woman who also performed the Darśa sacrifice and is thus rightfully known as “Dārśī”? More on this below.
And then comes the most interesting sūtra:
tasyā yāvad uktam āśīr brahmacaryam atulyatvāt (6.1.24).
“To the wife pertain only those functions that are distinctly laid down for her, – as also the 'invoking of blessings' and 'celibacy'; because she is not equal (to the husband).”
Commentary: darśa-pūrṇamāsābhyāṃ svarga-kāmo yajeta, jyotiṣṭomena svarga-kāmo yajetetyevamādiṣv etad uktaṃ strī-puṃsayoḥ sahādhikāra iti. athedānīṃ saṃdihyate, kiṃ sarvaṃ yājamānaṃ patnyā kartavyam, uta yāvad uktam āśīr brahmacaryaṃ ceti. kiṃ prāptam? sarvaṃ yājamānaṃ patnyāḥ syāt, sāpi hi yajamānā, tulyatvāt. tasmāt sarvaṃ tasyā iti. evaṃ prāpte brūmaḥ, tasyā yāvad uktaṃ syāt, vacana-prāmāṇyāt, āśīḥ brahmacaryaṃ ca syāt. kasmāt? atulyatvāt, atulyā hi strī-puṃsāḥ, yajamānaḥ pumān vidvāṃś ca, patnī strī cāvidyā ca.
kim ataḥ? yady evaṃ hy etad atulyatvam. etad ato bhavati, kratv-artheṣu yāni yājamānāni śravaṇāni, teṣūpādeyatvena śravaṇād vivakṣitaṃ liṅgam, tena teṣu patnī na syāt, yāni ca kratv-arthāni samantrakāṇi teṣv avidyatvāt patnī na syāt. tat patnyā adhyayanasya prayojakaṃ syād iti yady ucyeta. tan na, asaty api prayojakatve tasya nirvṛttir bhaviṣyati. asti hi tasya pumān nirvartakaḥ, yac ca kratv-artham, tad ekena yena kenacin nirvartayitavyam. tasmāt pratiṣiddhasya patnyā adhyayanasya punaḥ prasave, na kiṃcid asti pramāṇam. atas tad api patnī na kuryāt, yās tv āśiṣaḥ, yac ca brahmacaryam, tat puruṣaṃ prati guṇa-bhūtam, na tatrānyatareṇa kṛte sidhyati, anyatarasya hi saṃskāro hīyeta. na ca tatropādeyatvena yajamānasya śravaṇam. tasmāl liṅgam apy avivakṣitam. ata āśīr brahmacaryaṃ cobhayor api syāt. yac cāhatyocyate, yathā “patnyājyam avekṣata” iti. tasmād atulyatvād asamāna-vidhānā patnī yajamānena bhavitum arhatīti.
Translation: “In connection with such injunctions as — ‘darśapūrṇamāsābhyāṃ svargakāmo yajeta’ (‘Desiring heaven, one should perform the Darśa-pūrṇamāsa sacrifices’) and ‘jyotiṣṭomena svargakāmo yajeteta’ (‘Desiring heaven, one should perform the Jyotiṣṭoma sacrifice’) - it has been settled that the man and his wife are jointly entitled to the performance of such sacrifices. The doubt that arises now is – Are all the functions laid down as to be performed by the 'Sacrificer' to be performed the wife also? Or, is she to perform only what is actually laid down as to be done by her—such functions, for instance, as the 'invoking of blessings' and 'celibacy'?
[Pūrva-pakṣa]: “All that is laid down as to be done by the 'Sacrificer' (yājamāna) should be done by the wife also, she is as much a 'Sacrificer' (yājamāna) as the husband because she is equal [to him]. Therefore everything should be done by her also.”
[Siddhānta]: “To this we reply: To the wife pertain only such functions as are distinctly laid down
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for her, because such direct injunction is authoritative. She also has to perform the invoking of blessings and celibacy. Why so? Because she is not equal to the husband. The husband is a male and is learned [in the Vedas] while the wife is a female and is not learned.”
Question: ‘What if there is an inequality?
Answer: ‘What happens is this: – (a) There are certain details subserving the purposes of the sacrifice which are directly declared as to be performed by the “Sacrificer”;--and as in all these texts, the Sacrificer would be the 'Subject', the [masculine] gender of the term speaking of him would have to be regarded as significant.—and hence the wife would not perform these details; – (b) then, there are certain details subserving the purposes of the sacrifice which have to be performed with Mantras; – and these also could not be performed by the wife, because she does not possess the requisite knowledge.—It might be argued that—" these texts themselves might be taken as indicating the necessity of women learning the Veda ". – But that is not possible; because even without the text indicating the necessity of such learning by the wife, it would be possible for the details in question to be adequately performed; because there is a performer already, in the person of the Husband ; and what subserves the purposes of the sacrifice may he done by either one of the two. Consequently there can be no authority for making any exception to the general prohibition of Vedic study for the woman. —It follows therefore that such details as require the reciting of Mantras cannot be performed by the wife.
As regards the 'Invoking of blessings' [or, the Embellishments] and the 'celibacy',—these subserve the purposes of the performer; so that these could not be regarded as complete if done by only one of the couple; because if only one did them, the embellishment of the other would remain defective. Nor in the case of these does the 'Sacrificer' appear as the 'subject'; and hence the masculine gender in this case could not be taken as significant. —For these reasons, the 'Invoking of Blessings' (or, Embellishments) and 'Celibacy' would have to be done by both—husband and wife.
What is distinctly laid down as to be done by the wife—as for instance, 'the wife should examine the Clarified Butter'—has to he done by her alone.
From all this it follows that on account of inequality, the wife does not stand on the same footing as the husband (in the matter of the performance of details).” (End of translation, emphasis added).
This whole discussion from the Mīmāṁsā-sūtra was based on the śruti injunction cited many times by Āpastamba (“svarga-kamam yajeta” from Āpastamba-śrauta-sūtra), so here is what the same Āpastamba says about women directly offering oblations:
na strī juhuyāt[12]
“A woman should not offer oblation in the Agnihotra.” (Āpastamba-dharma-sūtra, 2.6.15.17)[13]
Or:
striyānupetena kṣāra-lavaṇāvarānna-saṃsṛṣṭasya ca homaṃ paricakṣate[14]
“They reject a sacrifice performed by a woman or by one who has not received the initiation, and a sacrifice of salt or pungent food, or of such food as has an admixture of a despised sort of food.” (Āpastamba-gṛhya-sūtra, 8.3)[15].
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“Later commentators also give the example that the statement 'brāhmaṇo na hantavyaḥ‘ — a brāhmaṇa should never be killed — also includes a brāhmaṇī. This shows that even though male species may be indicated in an aphorism, it often includes females. ”
Although no mention is made as to who those later commentators are and what text they commented upon, this prohibition from dharma-śāstras is mentioned by Patañjali in his Mahābhāṣya commentary on Pāṇini's Aṣṭādhyāyī (1.2.64).
Still, as we saw in the mīmāṁsā-sūtra discussion above, the gender is sometimes crucial and sometimes not. In order to understand each case, an ācārya or commentator is needed. So a mere example of “brāhmaṇo na hantavyaḥ” does not in fact establish proper hermeneutics for all cases.
It appears from the śāstra that in relation to women this rule is sometimes applicable and sometimes not.
For instance, according to the Vasiṣṭha-dharma-sūtra, which was also quoted in the paper and will also be treated below, it is applicable only when the woman is ātreyī (has bathed after her menses) or if she is engaged in a sacrifice[16]:
brāhmaṇīṁ cātreyīṁ hatvā savana-gatau ca rājanya-vaiśyau
“If someone kills a Brahmin woman who is an Ātreyī or a Kṣatriya or a Vaiśya engaged in performing a sacrifice, [the penance is the same as for a Brahmin].” (20.34).
Otherwise, for killing a woman at a time other than directly after her menstrual period different penance is prescribed, which again shows inequality:
anātreyīṁ rājanya-hiṃsāyām - “For killing a Brahmin woman at a time other than after her menstrual period, the penance is the same as for killing a Kṣatriya man.” (20.37)
rājanyāṁ vaiśya-hiṃsāyām - “For killing a Kṣatriya woman, the same as for killing a Vaiśya man.” (20.38)
vaiśyāṁ śūdra-hiṃsāyām - “And for killing a Vaiśya woman, the same as for killing a Śūdra man.” (20.39)
śūdrāṁ hatvā saṃvatsaram - “If someone kills a Śūdra woman, he should perform the same penance for one year.” (20.40)
Moreover, the original sūtra contained the name of a sacrifice, 'Pūrṇa-māsa‘. Ladies who performed these sacrifices are thus rightfully known as 'Paurṇa-māsī‘.
Standard dictionaries (Sanskrit thesauri like Amara-koṣa (1.4.265) and Śadba-kalpa-druma, or Sanskrit-English dictionaries like those of Apte, Monier-Williams or MacDonell) do not mention this meaning of this word at all. All of them agree that the word means “the day of full moon.”
And here is the derivation of the word given by Śrīla Jīva Gosvāmī in his Hari-nāmāmṛta-vyākaraṇa (sūtra 1133 (or 2423 in the full Bṛhat version), translation by Matsyāvatāra prabhu):
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so ’tra vartata iti pūrṇamāsāt keśava-ṇaḥ, anyāyāder mādhava-ṭhaḥ
saḥ—that; atra—in this; vartate—occurs; iti—thus; pūrṇa-māsāt—after the word pūrṇa-māsa (“full moon”); keśava-ṇaḥ—the pratyaya keśava [ṇ]a;anyāya-ādeḥ—after the words anyāya (“injustice”) and so on; mādhava-ṭhaḥ—the pratyaya mādhava ṭha.
“Keśava [ṇ]a is applied after the word pūrṇa-māsa in the meaning “that occurs in this,” and mādhava ṭha is applied after the words anyāya and so on in the same meaning.”
Vṛtti (explanation) by Śrīla Jīva Gosvāmī: paurṇamāsī tithiḥ, ānyāyikaḥ autpātikaḥ nāva-yajñikaḥ.
Translation of the Vṛtti—Thus we get paurṇamāsī tithiḥ (“the lunar day in which the full moon occurs”). Examples of anyāyāder mādhava-ṭhaḥ are ānyāyikaḥ (“that in which an injustice occurs”), autpātikaḥ (“that in which a calamity occurs”), and nāva-yajñikaḥ (“that [time] in which an offering of the first-fruits of the harvest occurs”).
Amṛtāsvādinī-ṭīkā (Commentary by Gopāla dāsa): When we have the meaning pūrṇamāso ’tra vartate (“a full moon occurs in this”), we get paurṇamāsī. Similarly, when we have the meaning anyāyo ’tra vartate ānyāyikaḥ (“an injustice occurs in this”),we get ānyāyikaḥ, and so on[17].
MANU-SAMHITA
Srila Prabhupada often quoted the following selections from Manu-saṁhitā [7] :
na strī svātantryam-arhati (9.3)
Women should not be given independence.
And also,
pravṛttir eṣa bhūtānāṁ nivṛttis tu mahā-phalaḥ (5.56)
Everyone in material life is attracted to furthering the way of attachment (pravṛtti-mārga),
but the greatest treasure is to be gained by following the path of detachment (nivṛtti-mārga).
However, Srila Prabhupada did not always support the conclusions of this literature:
Yes, but we do not keep him śūdra. A devotee is no longer śūdra. We are creating brāhmaṇas.
Just like these Europeans and Americans. They, according to Manu-saṁhitā, are mlecchas,
yavanas. But we are not keeping them mlecchas and yavanas. Just like these European and
American boys. They are accepting the Vedic regulative principles: no illicit sex, no meat-
eating, no intoxication, no gambling. So they are no more śūdras or caṇḍālas. They are
brāhmaṇas. (Room Conversation, 5 June 1974.)
According to the Manu-saṁhitā you are all mlecchas and yavanas. You cannot touch the Manu-
saṁhitā, what to speak of translating it. So if you try to follow the Manu-saṁhitā then you
become a mleccha and yavana and your career is finished. (Secretary‘s letter to Madhusudana,
19 May 1977.)
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Śrīla Prabhupāda may have not always supported all the conclusions of the Manu-saṁhitā (although this is debatable), but he definitely supported at least its conclusions regarding the duties of women by repeatedly referring to Manu-saṁhitā in this regard.
CONTRADICTIONS
Manu-saṁhitā says different things about women. Sometimes its thrust is to speak highly of
them:
prajanārthaṁ mahā-bhāgāḥ pūjārhā gṛha-dīptayaḥ (9.26)
Women are to be worshipped. They are extremely auspicious. They are the illuminators of
the home.
yatra nāryastu pūjyante ramante tatra devatāḥ
yatraitāstu na pūjyante sarvās-tatrāphalāḥ kriyāḥ (3.56)
Wherever women are worshipped, the demigods reside, and wherever they are not
worshiped, all activities end in failure.
While some other sections speak derogatorily:
pauṁścalyāc cala cittāc ca naisnehyāc ca svabhāvataḥ (9.15)
Women are by nature adulterous, fickle-hearted, and devoid of all love.
nirindriyā hy amantrāś ca striyo ’nṛtam iti sthitiḥ (9.18)
Women are to be considered as devoid of all sense, devoid of all mantras, and full of falsity.
Sometimes we even find both kinds of statements in the same chapter — Chapter 9. No statement is offered directly in Manu-saṁhitā that resolves this incongruity.
But Śrīmad Bhāgavatam also “speak derogatorily”, for example:
kvāpi sakhyaṁ na vai strīṇāṁ vṛkāṇāṁ hṛdayaṁ yathā
“...you should know that the heart of a woman is like that of a fox. There is no use making friendship with women.” (9.14.36)
striyo hy akaruṇāḥ krūrā durmarṣāḥ priya-sāhasāḥ
ghnanty alpārthe 'pi viśrabdhaṁ patiṁ bhrātaram apy uta
“Women as a class are merciless and cunning. They cannot tolerate even a slight offense. For their own pleasure they can do anything irreligious, and therefore they do not fear killing even a faithful husband or brother.” (9.14.37)
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Should we also reject Śrīmad-Bhāgavatam because of that? Of course not. Rather, we should see that there is an agreement between the Manu-saṁhitā and the Bhāgavatam. These statements may seem “derogatory” but actually they are not—no spiritual authority (ācārya or śāstra) will ever speak of women derogatorily.
Śrīla Prabhupāda gives us the proper perspective on how to resolve this “apparent incongruity”:
“Good population in human society is the basic principle for peace, prosperity and spiritual progress in life. The varṇāśrama religion's principles were so designed that the good population would prevail in society for the general spiritual progress of state and community. Such population depends on the chastity and faithfulness of its womanhood. As children are very prone to be misled, women are similarly very prone to degradation. Therefore, both children and women require protection by the elder members of the family. By being engaged in various religious practices, women will not be misled into adultery. According to Cāṇakya Paṇḍita, women are generally not very intelligent and therefore not trustworthy. So the different family traditions of religious activities should always engage them, and thus their chastity and devotion will give birth to a good population eligible for participating in the varṇāśrama system. On the failure of such varṇāśrama-dharma, naturally the women become free to act and mix with men, and thus adultery is indulged in at the risk of unwanted population. Irresponsible men also provoke adultery in society, and thus unwanted children flood the human race at the risk of war and pestilence.” (Purport to Bhagavad-gītā 1.40).
And:
“A woman's nature has been particularly well studied by Kaśyapa Muni. Women are self-interested by nature, and therefore they should be protected by all means so that their natural inclination to be too self-interested will not be manifested. Women need to be protected by men. A woman should be cared for by her father in her childhood, by her husband in her youth and by her grown sons in her old age. This is the injunction of Manu, who says that a woman should not be given independence at any stage. Women must be cared for so that they will not be free to manifest their natural tendency for gross selfishness. There have been many cases, even in the present day, in which women have killed their husbands to take advantage of their insurance policies. This is not a criticism of women but a practical study of their nature. Such natural instincts of a woman or a man are manifested only in the bodily conception of life. When either a man or a woman is advanced in spiritual consciousness, the bodily conception of life practically vanishes. We should see all women as spiritual units (ahaṁ brahmāsmi), whose only duty is to satisfy Kṛṣṇa. Then the influences of the different modes of material nature, which result from one's possessing a material body, will not act.” (Purport to Śrīmad-bhāgavatam 6.18.42).
As for different kinds of statements in the Manu-saṁhitā—that alone is not a solid reason to altogether reject it as non-authoritative. One may easily understand and relate to the praise of women—they should be protected and respected, at the same time one may not so easily relate to the negative statements. However, such negative statements about women are present in many Vedic scriptures (sometimes even word for word). As we understand from Śrīla Prabhupāda's purport quoted above all these statements are meant to ensure women's protection.
We do not want to focus on these statements, however just to give an example we will reproduce some of them here:
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tasmāt striyo nirindriyā adāyādīr api pāpāt puṁsa upastitaram (Kṛṣna Yajurveda, Taittirīya-saṁhitā, 6.5.8.10)
“Therefore women are powerless, have no inheritance, and speak more humbly than even a bad man”[18] (compare with the Manu-smṛti, 9.18 cited above).
Such “derogatory” statements about women are also there in the Ṛg-veda, which has many hymns composed by the female Ṛṣis. If the contradictory statements about women are sound reasons for a scripture to be considered interpolated then we will also have to put the Ṛg-veda, which has been accepted by the authors as authoritative, in the same category. The authors quoted two verses from the 10th Maṇḍala of Ṛg-veda to show that women have qualification to speak on transcendental topics, however
the same 10th Maṇḍala also says the following “derogatory” things about women:
na vai straiṇāni sakhyāni santi sālāvṛkāṇāṁ hṛdayānyetā (Ṛg-veda, 10.95.15)[19]
“With women there can be no lasting friendship: hearts of hyenas are the hearts of women.” (Compare with the verses from the Śrīmad-Bhāgavatam (9.14.36-37) quoted above).
This is a hymn composed by Urvaśī (the Ṛṣi of this sūkta), who is a woman herself and thus she probably knows what she is speaking about. Also, according to the authors, she must have “taught and initiated others in these hymns, for only the creator of a hymn or those coming in the creator's disciplic succession can initiate others”, so we can safely assume that Manu-smṛti and similar works got this knowledge from such śrutis. A few other examples:
abhrātaro na yoṣaṇo vyantaḥ patiripo na janayo durevāḥ
pāpāsaḥ santo anṛtā asatyā idam padam ajanatā gabhīram (Ṛg-veda, 4.5.5)
“Like youthful women without brothers, straying, like dames who hate their lords, of evil conduct, They who are full of sin, untrue, unfaithful, they have engendered this abysmal station.”
indraś cid ghā tad abravīt striyā aśāsyaṁ manaḥ
uto aha kratuṁ raghum (Ṛg-veda, 8.33.17)
“Indra himself hath said, The mind of woman brooks not discipline, Her intellect hath little weight.”
strīr eva tad-anugāḥ kurute tasmāt striyaḥ pumso ’nuvartmāno bhāvukāḥ (Śukla Yajurveda, Śatapatha-brāhmaṇa, 13.2.2.4)
“He thereby makes women to be dependent, whence women are sure to be attendant upon man.”[20]
So, nothing wrong with Manu on this.
INTERPOLATIONS
Taking note of this and other points, various scholars have opined that the Manu-saṁhitā we see today has suffered from considerable interpolation.
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Again, we are not told who those “various scholars” are. Śrīla Prabhupāda or any other previous ācārya never said this. A scholar named Patrick Olivelle, who is a famous authority on the Dharma-śāstra in the secular world, prepared the Critical Edition of the Manu-smṛti. He discusses there possible contradictions and interpolations and here is what he says about Chapter Nine that has both kinds of statements (“derogatory” and “high”):
“Chapter Nine: This chapter addresses the last three grounds for litigation: marital law, inheritance, and gambling. The sections on marital law and inheritance are remarkably free of obvious redactoral interventions.” (Olivelle, Patrick. 2004. The Law Code of Manu. New York: Oxford University Press. p.51).
There of course might have been some cases of interpolation, but as we shall see below, it certainly wasn't that “considerable”.
In the introduction to the earliest known commentary on the Manu-saṁhitā by Medhatithi, we find the following verse written by the scribe of the commentary:
mānyā kāpi manu-smṛtis-tad-ucitā vyākhyāpi medhātitheḥ
sā luptaiva vidher-vaśād kvacid-api prāpyaṁ na tat-pustakam
kṣoṇīndro madanaḥ sahāraṇa-suto deśāntarād-āhṛtaiḥ
jīrṇoddhāram-acīkarat tata itas-tat-pustakair likhyate
Earlier, there was another Manu-saṁhitā with a suitable commentary by Medhatithi. That is, however, lost now due to the influence of providence and is no longer available. The king named Madana, the son of Sahāraṇa, procured some scattered portions from various places and the remaining book was rewritten.
First, this verse does not say at all that “there was another Manu-saṁhitā”. It simply says that Manu-smṛti is “mānyā” - venerable.
Second, Medhatithi's commentary with most certainty is not the earliest commentary—it was preceded by Bhāruci's commentary (see below).
This section of the paper offers an interesting methodology—no ācārya, no authority has ever said that present Manu-saṁhitā is different from the original version and only because some scribe in some manuscript says that, and we are now obliged to accept that without question, as if it were a Vedic injunction. On the contrary, there is ample evidence that current editions of Manu-smriti have changed little over time if they have changed at all.
This issue is also addressed by Prof. V.P. Kane in his “History of the Dharma-śāstra”, Vol.1, p.269:
“In several Mss. of the bhāṣya at the end of several adhyāyas occurs a verse which says that a king named Madana, son of Sahāraṇa, brought copies of Medhātithi's commentary from another country and effected a restoration (jīrṇoddhāra). This does not refer to the restoration of the text of Medhātithi, but to the completion of the library of the king, who was Madanapāla, son of Sadhāraṇa and flourished, as we shall see later on, in the latter half of the 14th century. ”
“Later on” means on the p.381-389 of the same Vol.1. The Madanapāla, son of Sadhāraṇa (Sahāraṇa in 
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* See:
 Kane, Vol.1, p.264-268
 J.Duncan, P.Derrett (ed.), Bharuci's Commentary on the Manusmrti, Vol.1, Wiesbaden, 1975; pp.4-17.
 P.Olivelle, Dharmaśāstra: a textual history, in “Hinduism and Law: An Introduction”, Edited by Timothy Lubin, Donald R. Davis and Jayanth K. Krishnan. Cambridge University Press: 2010, pp.52-54.

Prakrit) was the king and a great patron of learned men and is attributed with several works, many of which were actually composed by his protege Viśveśvara Bhaṭṭa, the most famous of them is Madana-pārijāta—which is a work on smṛti. Madanapāla also compiled an Ayurvedic work called “Madana-vinoda-nighaṇṭu”, which is a dictionary of drugs. Besides that he also wrote several works on astronomy, among which - a commentary on Sūrya-siddhānta “Sūrya-siddhānta-viveka” completed in 1402 AD.
It is established that Medhātithi lived not earlier than 820 AD and not later than 1050 AD (Kane, Vol.1, p.275). So even if we still doubt that Medhātithi's commentary and his version of Manu-smṛti is different from the present version, such doubts have no ground whatsoever because besides Medhātithi there were many other old commentators of the Manu-smṛti, like for example:
- Bhāruci, 7th-9th AD, who is identified as one of the proponents of the Viśiṣṭādvaita philosophy before Rāmānuja*.
- Govindarāja, ca. 1050-1100 AD;
- Kullūka Bhaṭṭa, ca.1150-1300 AD;
Their readings almost entirely agree with Medhātithi's (exept for several verses that are not commented upon by Medhātithi), and Kullūka Bhaṭṭa usually follows Medhātithi in his commentary while Medhatithī in many ways follows Bhāruci. None of them mention that previously there was another, different version of the Manu-saṁhitā. So if their versions agree with that of Medhātithi, then how could Madanapāla arrange “rewriting the remaining book” in 14th century AD?
Or, in words of Prof. Kane (Vol.1, p.273): “From Medhātithi's bhāṣya it is perfectly clear that the text of Manu on which he commented was practically the same that we have now.”
Another proof is that there is another very famous dharma-śāstra called Yājñavalkya-smṛti which, according to scholars (Kane, Olivelle) was “written” not later than 9th century AD. Here is what they say about it:
“Yājñavalkya (1.4) places Manu at the head of his list of the authors of Dharmaśāstras, the first such list in existence. Yājñavalkya's dependence on the MDh has been considered in detail by Kane (1960-75, I: 430) and I agree fully with his conclusion: "The correspondence of Yājñavalkya's words with the text of Manu is in most cases very close, so much so that one cannot help feeling that Yāj. had the Manusmṛti before him and purposely made an attempt to abridge the some loose expressions of Manu." Indeed, the abridgment and the tighter organization of the material are the main features of Yājñavalkya. He has between 1003 and 1010 verses depending on the recension, as opposed to the 2680 in the MDh. We have clear examples of Yājñavalkya's making a single pithy verse out of several prolix ones of Manu.” (Olivelle, Patrick. 2004. The Law Code of Manu. New York: Oxford University Press. p.67).
Manu-smṛti did not deserve such attack and criticism by the authors of the paper we are critiquing. No one in ISKCON seems to try to introduce its teachings about prayascittas, śrāddha etc. But we just cannot deny that Śrīla Prabhupāda referrred to Manu almost every time he spoke about women's duties. A mere search
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in the Vedabase among his vāṇī for the words Manu-smṛti or Manu-saṁhitā returns more than fifty references, and the great majority of them are related to the protection of women and, less, to the capital punishment of murderers and general praise of Manu-saṁhitā. For instance:
“The revealed scriptures, like Manu-saṁhitā and similar others, are considered the standard books to be followed by human society.” BG, 3.21p.
“As for behavior, there are many rules and regulations guiding human behavior, such as the Manu- saṁhitā, which is the law of the human race. Even up to today, those who are Hindu follow the Manu-saṁhitā. Laws of inheritance and other legalities are derived from this book. Now, in the Manu-saṁhitā it is clearly stated that a woman should not be given freedom. That does not mean that women are to be kept as slaves, but they are like children. Children are not given freedom, but that does not mean that they are kept as slaves. The demons have now neglected such injunctions, and they think that women should be given as much freedom as men. However, this has not improved the social condition of the world. Actually, a woman should be given protection at every stage of life. She should be given protection by the father in her younger days, by the husband in her youth, and by the grown-up sons in her old age. This is proper social behavior according to the Manu-saṁhitā. But modern education has artificially devised a puffed—up concept of womanly life, and therefore marriage is practically now an imagination in human society. The social condition of women is thus not very good now, although those who are married are in a better condition than those who are proclaiming their so-called freedom. The demons, therefore, do not accept any instruction which is good for society, and because they do not follow the experience of great sages and the rules and regulations laid down by the sages, the social condition of the demoniac people is very miserable.” BG16.7p.
“The Manu-saṁhitā is the standard lawbook for humanity, and every human being is advised to follow this great book of social knowledge.” SB2.1.36p.
“The conclusion is that if we want real peace and order in the human society, we must follow the principles laid down by the Manu-saṁhitā and confirmed by the Supreme Personality of Godhead, Kṛṣṇa.” SB7.8.48p.
And this one is especially relevant here:
“As we learn from the history of the Mahābhārata, or "Greater India," the wives and daughters of the ruling class, the kṣatriyas, knew the political game, but we never find that a woman was given the post of chief executive. This is in accordance with the injunctions of Manu-saṁhitā, but unfortunately Manu-saṁhitā is now being insulted, and the āryans, the members of Vedic society, cannot do anything. Such is the nature of Kali-yuga.” (SB10.4.5p).
So this is what is most important for us—Śrīla Prabhupāda spoke many times from Manu-saṁhitā and especially in relation to the protection of women. One cannot prove that Manu-saṁhitā is entirely non bona-fide simply by juxtaposing quotations about mlecchas and women.
NOT APPLICABLE IN KALI YUGA
Even if one were to believe that the Manu-saṁhitā that is found today is not an interpolated version of the
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* See: T.A.Strange, Hindu Law, London, 1830, p.xii.
original one, one would still be discouraged to accept it as a current authority by the following statement of the Parāśara-smṛti
kṛte tu mānavā dharmās tretāyāṁ gautamāḥ smṛtāḥ
dvāpare śāṅkhalikhitāḥ kalau pārāśarāḥ smṛtāḥ (1.24)
The Manu-saṁhitā is applicable in Satya-yuga, the Gautama-smṛti is applicable in Tretā-yuga, the Śaṅkha-likhita-smṛti is applicable in Dvāpara-yuga and the Parāśara-smṛti is applicable in Kali- yuga.
Unfortunately, we are not provided here with any examples from the Parāśara-smṛti to see how it is different from Manu-saṁhitā and what exactly makes it applicable in Kali-yuga to the extent that is becomes even more applicable than the Manu-smṛti. In fact, although stating that Mānava-dharma is for Kali-yuga, Parāśara-smṛti refers to Manu so many times that one cannot help but think that Manu is the foremost authority on Dharma that Parāśara encourages us to follow. (For some examples of such quotes—see the “History of Dharma-sastra”, Vol.1, p.194).
Besides that, Parāśara-smṛti[21] (9.51) calls Manu “the knower of all scriptures”:
manunā caivam ekena sarvaśāstrāṇi jānatā
prāyaścittaṃ tu tenoktaṃ goghnaś cāndrāyaṇaṃ caret
“The performance of a Chandrayana has been enjoined by Manu, the only one who knew all the scriptures, as an expiation, under any circumstance, for the sin of cow killing.” [emphasis added]
As for the Parāśara-smṛti being the main dharma-śāstra for the Kali-yuga—it is in fact debatable, considering that Manu-smṛti is highly comprehensive and fully describes all the details of different divisions of dharma, while Parāśara-smṛti is much lesser and does not describe all the intricacies of dharma. In fact the section on Vyavahāra, which must describe legal procedures, is entirely absent from the Parāśara-smṛti (this was analyzed as early as 1830 by T.Strange in the Preface to his book “Hindu Law”*).
So, here are some relevant quotes from the Parāśara-smṛti:
It also sometimes “speak highly” about women:
striyo vṛddhāś ca bālāś ca na duṣyanti kadācana (7.35)
“Women, old people and children are never contaminated.”
And it also prescribes their dependence on the husband:
daridraṃ vyādhitaṃ mūrkhaṃ bhartāraṃ yāvamanyate
sā śunī jāyate mṛtvā sūkarī ca punaḥ punaḥ (4.16)
“That wife who disrespects her husband because of his poverty, disease or ignorance, after death again and again becomes a female dog and a pig.”
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§ In his Dig-darśini-ṭīkā commentary to Hari-bhakti-vilāsa (12.73-74) Śrīla Sanātana Gosvāmī quotes this verse along with a verse from the Manu-smṛti (5.155): nāsti strīṇāṁ pṛthag yajño na vrataṁ nāpyupoṣaṇam, patiṁ śuśrūṣate yena tena svarge mahīyate—“No sacrifice, no vow, no fast must be performed by women apart from their husbands; if a wife obeys her husband, she will for that reason alone be exalted in heaven”. He explains that this verse refers to those who did not ask permission from their husbands or to those women who are not vaiṣṇavas.
patyau jīvati yā nārī upoṣya vratam ācaret
āyuṣyaṃ harate bhartuḥ sā nārī narakaṃ vrajet (4.17)
“That woman who undertakes a fasting vow when her husband is still living takes away the life span of her husband and goes to hell”§
apṛṣṭvā caiva bhartāraṃ yā nārī kurute vratam
sarvaṃ tad rākṣasān gacched ity evaṃ manur abravīt (4.18)
“If a woman without asking permission from her husband tooks up a vow, all the results of such vow go to the rākṣasas, thus Manu said.”
And it seems that Paraśara-smṛti is similarly “not so broad in its outlook”:
prāpte tu dvādaśe varṣe yaḥ kanyāṃ na prayacchati māsi māsi rajas tasyāḥ pibanti pitaraḥ svayam (7.5)
“If the girls has reached the age of twelve and the parents have not yet given her in marriage, they should personally drink her menstrual liquid month after month.”
mātā caiva pitā caiva jyeṣṭho bhrātā tathaiva ca trayas te narakaṃ yānti dṛṣṭvā kanyāṃ rajasvalām (7.6)
“The mother, father, elder brother of the girl—all these three go to hell if they see that her menstruation began.”
Śrīla Prabhupāda once mentioned this injunctions from the Parāśara-smṛti:
“I do not know exactly what is that śāstra, but they say that if the girl before marriage has menstruation, then the father has to eat that menstrual liquid.” (Morning Walk -- Māyāpur, February 9, 1976).
So the words of Śrīla Bhaktisiddhānta Sarasvatī Ṭhākura are very much relevant here:
“Moreover, the rules and regulations of a particular Dharma-śāstra were followed according to the particular place. In the opinion of some persons, at the beginning of the Kali age the Manu Dharma-śāstra and the doctrine of Parāśara Muni were prominently accepted, while the other twenty Dharma-śāstras were neglected. Others say that the doctrine of Hārīta was prominent and the activities prescribed by the other Dharma-śāstras were neglected. Generally, whatever one found convenient was accepted, without regard for other's consent and liking.” [bold emphasis added] (Brāhmaṇa and Vaiṣṇava, Prakṛti-jana-kāṇḍa[22]).
NOT A PRINCIPAL AUTHORITY
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A similar point is made by Srila Madhvācārya in his work Mahābhārata-tātparya-nirṇaya:
vaiṣṇavāni purāṇāni pañcarātrātmakatvataḥ
pramāṇāny eva manvādyāḥ smṛtayo ’py anukūlataḥ
Purāṇas which establish the supremacy of Vishnu are authority as they convey what is stated in Pañcarātra. Smṛti śāstras like those of Manu and others are also authority so far as they are consistent with these. (Part I)
As we have already shown above, Manu-saṁhitā is very much consistent with the best among the Vaiṣṇava Purāṇas – the Śrīmad-Bhāgavatam. Thus it is remarkably the only smṛti named by Madhvācārya (manv-ādyāḥ, but not “parāśara-ādyāḥ”, although Parāśara was the father of Vyāsa, Madhvācārya's guru, or hārīta-ādyāḥ). So, this also indirectly shows the preeminence of the Manu-smṛti over all other smṛtis.
Not only Śrī Madhva but many other ācāryas also mention and laud Manu-saṁhitā. Sanātana Gosvāmī quotes it many times in the Hari-bhakti-vilāsa (e.g. 1.92, 3.213, 3.310, 4.84, 4.351, 9.274, 11.796); Jīva Gosvāmī quotes it in his Tattva- and Bhakti-sandarbhas, as well as in his Gopāla-campū and Śrīdhara Svāmī even states in his commentary on the Śrīmad-bhāgavatam that Kṛṣṇa and Balarāma Themselves studied Manu-smṛti from Sandīpani Muni ('dharmān' manv-ādi-dharma-śāstrāṇi – commentary to 10.45.34).
Citing śruti (Taittirīya-saṁhita from the Kṛṣṇa-Yajur-veda), Baladeva Vidyābhūṣaṇa also defends the authority of Manu in his Govinda-bhāṣya (2.1.1):
manor āptatvaṁ tu taittirīyāḥ paṭhanti— “yad vai kiṁ ca manur avadat tad-bheṣajam” iti
“However, Manu is authoritative because it is said in the Taittirīya-saṁhitā (2.2.10.2) “whatever Manu has declared is a cure.”
The authors previously told us that Jaimini‘s Pūrva-mīmāṁsā sūtras are “a valid and acceptable authority” because “they have been referred to by many ācāryas in their works, e.g. Srila Jiva Goswami in his Kṛṣṇa-sandarbha and Srila Baladeva Vidyabhushan in his Govinda-bhāṣya”, but here we see that those very ācāryas also refer to the Manu-saṁhitā, then why the authors want us to reject it?
So, we just cannot dismiss the words of our Founder-Ācārya:
“As we learn from the history of the Mahābhārata, or "Greater India," the wives and daughters of the ruling class, the kṣatriyas, knew the political game, but we never find that a woman was given the post of chief executive. This is in accordance with the injunctions of Manu-saṁhitā, but unfortunately Manu-saṁhitā is now being insulted, and the āryans, the members of Vedic society, cannot do anything. Such is the nature of Kali-yuga.” SB10.4.5p.
Another smṛti says:
vedārtha-pratibaddhatvāt prāmānyaṃ tu manoḥ smṛtam
manv-artha-viparītā yā smṛtiḥ sā na praśasyate
“Manu, however, is the authority, the tradition declares, because he is firmly anchored to the
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meanings of the Vedas. Any smṛti opposed to the tenor of Manu is not approved.” (Bṛhaspati-smṛti as quoted in “Olivelle, Patrick. 2004. The Law Code of Manu. New York: Oxford University Press. p.69”).
APPARENT CONTRADICTION IN THE HARI-BHAKTI-VILĀSA
POSITIVE EVIDENCE
tāntrikeṣu ca mantreṣu dīkṣāyāṁ yoṣitām api
sādhvīnām adhikāro ’sti śūdrādīnāṁ ca sad-dhiyām (1.194)
In all matters of initiations in tantras and mantras, saintly ladies have all rights, and so do the śūdras and others who are dedicated to serving their spiritual masters. (The word 'adhikāraḥ‘ is to be noted in the original Sanskrit.)
āgamoktena mārgeṇa strī-śūdrair api pūjanam
kartavyaṁ śraddhayā viṣṇoś cintayitvā patiṁ hṛdi (1.195)
Through the path shown in the āgamas, ladies and śūdras can also worship the deities. They should faithfully perform such worship, thinking about their respective Lords in their hearts.
strīṇām apy adhikāro 'sti viṣṇor ārādhanādiṣu
pati-priya-ratānāṁ ca śrutir eṣā sanātanī (1.197)
Ladies too have all right to conduct the worship, etc., of Lord Vishnu, and so do those girls who are unmarried and desire a suitable husband. This is the verdict of the eternal śruti. (Again, the word 'adhikāraḥ‘ is to be noted in the original Sanskrit.)
agastya-saṁhitāyāṁ śrī-rāma-mantra-rājam uddiśya—
śucivratatamāḥ śūdrā dhārmikā dvija-sevakāḥ
striyaḥ pati-vratāś cānye pratilomānulomajāḥ
lokāś cāṇḍāla-paryantāḥ sarve ’py atrādhikāriṇaḥ (1.198)
In the Agastya Saṁhitā, indicating the Śrī-rāma-mantra-rāja, it is said, “All have equal qualification for this mantra, whether they be a śūdra who is dedicated to his vows and eager to serve the brāhmaṇas, ladies who are dedicated to their husbands, or dog-eaters who are born of any type of marriage (pratiloma or anuloma).
svapna-labdhe striyā datte mālā-mantre ca try akṣare
ekākṣare tathā mantre siddhādīn naiva śodhayet (1.211)
One should not ritually purify a mantra obtained in a dream, a mantra given by a woman, a mālā-mantra [a mantra of over twenty syllables] or mantras of one or three syllables for siddha and so on.
gṛhasthā vanagāś caiva yatayo brahmacāriṇaḥ
striyaḥ śūdrādayaś caiva sarve yatrādhikāriṇaḥ (1.218)
The gṛhastha, vānaprastha, sannyāsī, brahmacārī, ladies and śūdras are all eligible to receive the [Gopāla] mantra. (The word 'adhikāriṇāḥ‘ is again to be noted in the original Sanskrit.)
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striyo vā yadi vā śūdrā brāhmaṇāḥ kṣatriyādayaḥ
pūjayitvā śilā-cakraṁ labhante śāśvataṁ padam (Hari-bhakti-vilāsa 5.452)
All attain to the eternal spiritual world by worshipping the śālagrāma-śilā, whether a lady, a śūdra, brāhmaṇa, kṣatriya, etc.
NEGATIVE EVIDENCE
yoṣito nāvamanyeta na cāsāṁ viśvased budhaḥ
na caiverṣyur bhavet tāsu nādhikuryāt kadācana (Hari-bhakti-vilāsa 11.708)
A wise man should not disregard, nor put faith in a woman. He should not become envious of them and should never give them any authority or rights. (Emphasis added.)
RESOLVING THE CONTRADICTION
The compound word nādhikuryāt in the negative evidence directly contradicts the word adhikāriṇāḥ in the previous positive evidence. How to resolve this contradiction?
The emphasis on the word adhikāra here is artificial. It has a broad range of meanings. For instance, Apte's dictionary[23] tells us that the word means: “superintendence”, “position”, “authority”, “watching over” and then also “a right”, “authority”, “a qualification”, “a claim”, “privilege”. So in one case it is used in the sense of “right” and in another—in “position of authority”. When someone has a right to something (adhikārī) it does not necessarily mean that he is in a position of authority (as a superintendent). Depending on the context, the word means different things. The authors apparently have not considered this.
Thus in the first set of quotes the adhikāra is “eligibility” for worship and receiving the mantra, while in another the adhikāra is the “power” or “authority” that is not to be given to women. Thus, the contradiction is only apparent.
“The nādhikuryāt kadācana statement in the Hari-bhakti-vilāsa which speaks against women being given authority or rights has been taken from the Viṣṇu-purāṇa. A closer look at the current editions of the Viṣṇu-purāṇa gives the original Sanskrit text of the statement in a different way that completely changes the meaning:
In the Viṣṇu-purāna editions published by two separate publishers, the same verse is found as follows,
yoṣito nāvamanyeta na cāsāṁ viśvased budhaḥ
na caiverṣyā bhavet tāsu na dhik kuryāt kadācana (3.12.30)
A wise man should neither disregard nor put faith in a woman. He should not become envious of them and should never curse them. (Emphasis added.)
A simple change from nādhikuryāt kadācana to na-dhik-kuryāt kadācana (changing 'nā’ to 'na’ and 'ku’ to 'kku’) makes a world of difference in the way the verse is understood.
Some may be inclined to think that this version of na-dhik-kuryāt kadācana might be a recent interpolation
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* See, for example: Viṣṇu Purāṇam, Śrīdhara Svāmī kṛta Sva-prakāśākhya-ṭīkā sahitam, edited by Jīvānanda Vidyāsāgara Bhaṭṭācārya, Kolkata, 1882 [“nādhikuryāt”] and Śrī Viṣṇupurāṇam, Viṣṇucittyātma-prakāśākhya Śrīdharīya vyākhyā-dvayopetam, Veṅkaṭeśvara Steam Press, Bombay, 1907 [“na dhik kuryāt”].
in the Viṣṇu-purāṇa. However, in the commentary of Śrīla Śrīdhar Svāmī (written sometime between 1350 and 1450 AD) on this verse of Viṣṇu-purāṇa the alternate reading is recognized:
na dhik kuryāt dhik-kāraṁ na kuryāt (commentary on the same verse)
‘Na dhik kuryāt’ means one that should not curse them.
In this way all of the statements of Hari-bhakti-vilāsa can be reconciled.
Unfortunately resorting to variant readings from the Viṣṇu Purāṇa does not in fact resolve this apparent “contradiction” in the Hari-bhakti-vilāsa but gives rise to another question: How should we understand that Sanātana Gosvāmī and Gopāla Bhaṭṭa Gosvāmī intentionally or unknowingly used the reading of the verse that causes contradiction and then commented upon it without mentioning or resolving the possible contradiction?
Other points to consider:

The reading “na dhik kuryāt” is not a standard one as given in the Critical Edition of the Viṣṇu Purāṇa[24], which means that only a minority of manuscripts gives this reading;

Different editions of Śrīdhara Svāmī's commentary on the Viṣṇu Purāṇa have completely different commentaries to these two alternate readings of the verse*, so obviously one of them could easily be such “recent interpolation”. Given the fact that Hari-bhakti-vilāsa and most of the Viṣṇu-purāṇa manuscripts agree on the “nādhikūryat” reading, one may be inclined to stay with this version.

So, in such a situation without proper critical process we shall hardly know which reading of the verse is actually correct and was actually commented upon by Śrīdhara Svāmī.
OTHER SMRTIS AND ITIHASAS
There are a number of other smṛtīs that differ with the Manu-smṛti regarding women and their rights. A few examples:
WOMEN CAN CHANT GAYATRI
manasā bhartur-aticāre tri-rātraṁ yāvakaṁ kṣīraudanaṁ vā bhuñjānāghaḥ śayītordhvaṁ tri-rātrād-apsu nimagnāyāḥ sāvitry-aṣṭa-śatena śirobhir-juhuyāt-pūtā bhavatīti vijñāyate (Vasiṣṭha Smṛti [16] 21.7)
If a lady thinks ill of her husband in her mind, then she should keep barley grains for three nights in water and offer them along with flowers in sacrifice while chanting Gāyatrī for a hundred and eight times. Thus she becomes purified.
Unfortunately, Vasiṣṭha-smṛti does not actually support the idea that women can chant Gāyatrī. In this verse the past participle passive “nimagnāyāḥ” is in genitive case and the whole construction of the phrase is genitive absolute (sataḥ ṣaṣṭhī), meaning that the offerings and oblations with mantras should be done while the wife is immersed in water. In such state she cannot offer anything in fire.
So, it is actually such a wife, who should be eating (bhuñjānā) only barley (yāvakaṁ) or rice boiled in milk
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(kṣīraudanaṁ vā) for three days (“nights” - tri-rātraṁ) and sleep on the ground (adhaḥ śayītā) then (ūrdhvaṁ) after three nights (tri-rātrād) she should immerse herself in the water (apsu-nimagnāyāḥ) while her husband performs 800 oblations with Sāvitrī (gāyatrī) mantra and Śiraḥ-mantra (āpo jyotī raso'mṛtaṁ brahma bhūr bhuvaḥ suvar om namaḥ—both of these mantras are recorded in Taittirīya-Āraṇyaka, 10.35.1).
For comparison, here is a literal translation of the verses by G.Buhler[25] (which is also affirmed by P.Olivelle[26]):
manasā bhartur aticāre trirātraṁ yāvakaṁ kṣīrodanaṁ vā bhuñjānādhaḥ śayītordhvaṁ tri-rātrād apsu nimagnāyāḥ sāvitry-aṣṭa-śatena śirobhir juhuyāt pūtā bhavatīiti vijñāyate
“If (a wife) has been mentally unfaithful to her husband, she shall live on barley or rice boiled in milk during three days, and sleep on the bare ground. After the three days (have expired), the (husband) shall offer eight hundred burnt-oblations, (reciting) the Sāvitrī (and the Mantra called) Śiras, while she is immersed in water. It is declared in the Veda that she becomes pure (thereby).” (21.6).
Footnote to this sūtra by G.Buhler: “Afterwards in order to purify her who is immersed in water, i.e. has plunged into water, he shall offer eight hundred, i.e. (such) a number of burnt-oblations with the Śiras, i.e. (the words) "Om, ye waters, who are splendour, juice, and ambrosia," &c., which are joined to the Gāyatrī.'-- [the commentary by] Kṛṣṇapaṇḍita. The Śiras, or 'head,' is again mentioned below, XXV, 13; see also Vishnu LV, 9. This and the following two rules refer to offences committed with males of equal caste.”
vāk-saṁbandha etad eva māsaṁ caritvordhvaṁ māsād apsu nimagnāyāḥ sāvitryāś caturbhir aṣṭa-śataiḥ śirobhir juhuyāt pūtā bhavatīti vijñāyate.
“If (a wife) has held an (improper) conversation (with another man), she must perform the same penance during a month. After (the expiration of) the month, (the husband) shall offer four times eight hundred burnt-oblations, (reciting) the Sāvitrī (and the Mantra called) Śiras, while she is immersed in water. It is declared in the Veda that she becomes pure (thereby).” (21.7).
vyavāye tu saṁvatsaraṁ ghṛta-paṭaṁ dhārayed gomaya-garte kuśa-prastare vā śayītordhvaṁ saṁvatsarād apsu nimagnāyāḥ sāvitryaṣṭa-śatena śirobhir juhuyāt pūtā bhavatīti vijñāyate
“But if (a wife) has actually committed adultery, she shall wear during a year a garment smeared with clarified butter, and sleep on a mat of Kuśa grass, or in a pit filled with cow-dung. After (the expiration of) the year, (the husband) shall offer eight hundred burnt-oblations, (reciting) the Sāvitrī (and the Mantra called) Śiras, while she is immersed in water. It is declared in the Veda that she becomes pure (thereby).” (21.8).
Additional relevant information regarding Vasiṣṭha-smṛti:

Vasiṣṭha-smṛti equates women with śūdras at least in relation to the ācamana: strī-śūdraṁ spṛṣṭābhir eva ca—“Women and śūdras become pure simply by touching [the water]” (3.34). A similar quote appears in the Hari-bhakti-vilāsa (3.193) – strī-śūdrāvāsya-saṁsparśa-mātreṇāpi viśudhyataḥ – “Women and śūdras are purified by simply touching water to their mouth”.


The chapter on strī-dharma opens with the sūtra “asvatantrā strī puruṣa-pradhānā” (5.1) - “A woman

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is not independent, the males are her masters” and Vasiṣṭha further substantiates this statement by quoting the famous verse from the Manu-smṛti (9.3):

athāpy udāharanti:
pitā rakṣati kaumāre bhartā rakṣati yauvane
putraś ca sthavire bhāve na strī svātantryam arhati
“Now they quote also (the following verse): 'Their fathers protect them in childhood, their husbands protect them in youth, and their sons protect them in age; a woman is never fit for independence.” (Vasiṣṭha-smṛti, 5.3).
Besides this quotation, Vasiṣṭha directly quotes from or refers to Manu more than 50 times—much more than from anyone else! (For the detailed description—see The History of Dharma-sastra, Vol.1, pp.54-57).
So, the statement “Vasiṣṭha-smṛti differs from Manu regarding women and their rights” does not seem to be true.

While describing upanayana (in chapter 11) and studying the Vedas (in chapter 3) and the duties of women (chapter 5) Vasiṣṭha does not say a single word about women undergoing initiation (while he prescribes different ages for upanayana for different varṇas), so it is a question then—if they did not receive Gāyatrī and other mantras from the guru, how would they know it to utter 800 times as a prāyaścitta?

SAME RIGHTS IN VEDIC MANTRAS
Śrīla Madhvācārya quotes the Vyoma-saṁhitā in his Brahma-sūtra-bhāṣya (1.1.1) as follows,
āhur apy uttama-strīṇāṁ adhikāraṁ tu vaidike
yathorvaśī yamī caiva śacyādyaś ca tathāparā
Elevated ladies are definitely entitled to the Vedas, just like Urvaśī, Yamī, Śaci, etc.
An elaborate analysis of this topic (on the basis of the bhāṣya and its sub-commentaries) can be found elsewhere on the Internet.
And it is ironic that the authors quote Madhvācārya on this since we do not know any example of a famous historical woman saint in the Madhva-sampradāya.
TWO TYPES OF LADIES
The Hārita-smṛti, which is much older and broader in its outlook than the current edition of the Manu-smṛti, speaks about two types of women as follows,
dvividhāḥ striyaḥ. brahma-vādinyaḥ sadyo-vadhvaś ca. tatra brahma-vādinīnām upanayanam agnīndhanaṁ vedādhyayanaṁ sva-gṛhe-ca bhikṣācaryā iti. sadyo-vadhūnāṁ tūpasthite vivāhe kathañcid- upanayana-mātraṁ kṛtvā vivāhaḥ kāryaḥ (21.23)
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* For more information see:
1) Parāśara-dharma-saṁhitā with the commentary of Sāyaṇa-Mādhavācārya, edited by V.S. Islampurkar, 1893, Vol.1, p.16-17.
2) The Indian Antiquary, Vol.25 (1896), p.147-148;
3) V.P.Kane, The History of Dharma-sastra, Vol.1, pp.70-75.
There are two types of ladies — the brahmavādinī, who doesn‘t desire to marry, and the sadyovadhū, who wishes to marry. For the brahmavādinī there is provision for receiving the sacred thread, conducting the fire sacrifice, studying the Vedas, and begging alms at her own home. The sadyovadhū at the time of marriage should only be invested with the sacred thread and then married.
We have partially discussed this section above. Again, as we have pointed out, the phrase “sva-gṛhe ca bhikṣācaryā” means that she should beg alms at her own home, while boys could go out to get bhikṣā—another evidence of inequality.
Moreover, this quote from Hārīta-smṛti is not complete, it is said further that the ceremony of samāvartana (finishing the education) for girls should be performed before the appearance of menses (prāg rajasaḥ samāvartanam iti hārītoktyā – quoted in Vīramitrodaya, Saṁskāra-prakāśa, p.404). Prof. Kane writes about this quote as follows: “Therefore such brahmavadinī women had upanayana performed in the 8th year from conception, then they studied Vedic lore and finished student-hood at the age of puberty.” (History of Dharma-sastra, Vol.2, p.295). Even if we accept this somewhat unusual for dharma-śāstras statement as authentic, it is still just another example of inequality.
As for the Hārīta-smrṭi—there are several dharma-śāstras under the name of Hārīta-smṛti but this particular version of it that contains all these quotes (which is a sūtra work - Hārīta-dharma-sūtra) to the best of our knowledge has not yet been published and exists only in quotations scattered over different commentaries on dharma-śāstra and only a single manuscript of it has been found*. Given all this—that we still do not know the general outlook and contents of the work—how can we come to the conclusion that it is “much older and broader in its outlook than the current edition of the Manu-smṛti”?
Earlier the authors tried to prove that the original Manu-smṛti has been lost and therefore we should not rely upon it and here we are encouraged to rely on the Hārīta-smṛti, however the irony of it is that the Hārīta-smṛti has not yet really been found!
Another serious problem with the proposal that the current edition of Manu-smṛti is not “broad in its outlook” is the implication that anyone who accepts it as an authority (Śrīla Prabhupāda has certainly said that Manu-saṁhitā is an authority) must also be “not so broad in his outlook”.
Srila Thakur Bhaktivinode makes similar points about different types of ladies:
strī-loka śuddha-bhakta ha-ile anya strī-lokake nāma vijñayera pasārī ha-ite pārena. puruṣādigake
nāma dite pārena nā. tabe adhika bayaḥprāptā mānyā strī sthala-viśeṣe satarka tāra sahita puruṣa-
digera nikaṭa nāma vikraya karite pārena. nāma pracāra-sthale vṛddhā o bālikā strī vyatīta
sambandha-rahita anya strī-lokake kona puruṣa-pracāraka avalokana vā sambāṣaṇa karibena nā.
Women who are pure devotees can also become traveling saleswomen for distributing the holy name, but they cannot give the holy name to men. According to time, place and circumstance, and with great care and caution, mature women can distribute the holy name to men. Apart from
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elderly women or very young girls, men preachers should avoid discussion with women. (Godruma- kalpāṭavī)
strī-lokera gṛhasthāśrama o sthala-viśeṣe vānaprastha vyatīta anya kona āśrama svīkartavya naya.
kona āsādhāraṇa-śakti-sampannā strī vidya, dharma o sāmarthya lābha kariyā yadi brahmacarya vā
sannyāsa-āśrama grahaṇa kariyā sāphalya-lābha kariyā thākena vā lābha karena, tāhā sādhāraṇataḥ
komalaśraddha, komalaśarīra o komalabuddhi strī jātira pakṣe vidhi nahe
Women are allowed to enter only the gṛhastha āśrama and in special cases the vānaprastha āśrama. Although some women, being exceptionally qualified by achieving high education, expertise in understanding the scripture, and the power of abstinence, may take to the brahmacārī or sannyāsī āśrama and obtain all success, it is not the normal rule, as women are usually of weaker body, faith, and discriminating power. (Caitanya-śikṣāmṛta, chapter 2, part 4)
And here is yet another quotation from Śrīla Bhaktivinoda Ṭhākura, which appears in his Bengali translation of the Saṁskāra-dīpika by Gopāla Bhaṭṭa Gosvāmī[27] where it is stated that even women can accept sannyāsa if they are qualified. In his translation Bhaktivinoda Ṭhākura gives his vision of it:
The original text of the Saṁskāra-dīpika :
...yathā śrī-maharabhoḥ pārṣadasya śrī-dāmodarasya śikhā-sūtra-tyāgena kaupīna-dhāraṇena ca (kintu) yoga-paṭṭanaṁ vinā sannyāsena svarūpākhyā abhūt. yathā śrī-mādhavī-vaiṣṇavī apīti. (22)
Bengali translation by Bhaktivinoda Ṭhākura (bold emphasis added):
yemana, śrī-mahāprabhura pārṣada śrī-dāmodarera yoga-paṭṭa vyatīta śikhā-sūtra-tyāga o kaupīna dhāraṇera dvārā sannyāsa-grahaṇe 'svarūpa' ākhyā haiyāchila. yemana, śrī-mādhavi vaiṣṇavī-o—ini gṛhe thākiyā cīra-khaṇḍa-dvaya grahaṇa-pūrvaka sannyāsa lābha kariyāchilena.
English translation:
“Just like Mahāprabhu's associate Śrī Dāmodara, who gave up his śikhā and sacred thread and accepted a loincloth but not the traditional saffron cloth of a sannyāsī, became known as Svarūpa after taking sannyāsa. Or just like Śrī Mādhavī, who although being a women, vaiṣṇavī, attained sannyāsa by taking two pieces of torn cloth and remaining at home.”
Pay attention to the bolded words in the Ṭhākura's translation above.
Although apparently Saṁskāra-dīpikā allows some women to take sannyāsa, Bhaktivinoda Ṭhākura in his translation shows the proper way to do that—and it is quite different from the way men take sannyāsa and leave home.
WOMEN ARE NOT ON THE LEVEL OF SUDRAS
There is sometimes an idea that women are on an equal level with śūdras or even lower than them. Hārita, too, in the same smṛti, rejects the idea by giving a solid argument as follows,
na śūdra-samāḥ striyaḥ. nahi śūdra-yonau brāhmaṇa-kṣatriya-vaiśyā jāyante. tasmāc-chandasā striyaḥ
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saṁskāryāḥ.
Ladies are not the same as śūdras. Why? Because it is not possible that brahmaṇas, kṣatriyas and vaiśyas will be born from the womb of a parent who is śūdra. Therefore, one must educate and initiate ladies in all sacrifices [or else they‘ll become śūdras and there will be fear of everyone degrading into śūdras].
Although the argument appears to be solid and sounds like “broad-minded”, still one can easily notice the unspoken premise in it: “a brāhmaṇa is one who is born from a brāhmaṇa father and brāhmaṇī mother, and a śūdra is one who is born from the śūdra-yoni”, or, in other words, the same “caste by birth” consideration. Śrīla Prabhupāda repeatedly said “janmanā jāyate śūdraḥ saṁskārād bhaved dvijaḥ” - it does not matter which yoni (womb) one is born from, until the saṁskāras are performed by mere birth one is a śūdra.
Again, until we see this recension of the Hārīta-smṛti, we can retain doubts regarding its “broad outlook”, since in another, more well-known version of it, Laghu-hārīta-smṛti, there is a verse that also speaks about the same “birth considerations”:
brāhmaṇyāṁ brāhmaṇenaivam utpanno brāhmaṇaḥ smṛtaḥ
“The child born of a brāhmaṇa in the womb of a brāhmaṇa wife is known as a brāhmaṇa.” (Laghu- Hārīta-smṛti, 1.15, as quoted by Śrīla Bhaktisiddhānta Sarasvatī Ṭhākura in “Brahmana and Vaisnava”, Prakṛti-jana-kāṇḍa).
From another angle of vision this quote also does not really prove that people will not degrade into śūdras—because birth alone does not determine the varṇa, so given the fact that the women are not on the level of śūdras, it will not save their sons from degrading into śūdras because according to the śāstra, people in Kali-yuga are indeed degrading into śūdras, the only remedy is vaiṣṇava-dīkṣā and harināma. It is not that only by the birth from a non-śūdra woman, one automatically becomes non-śūdra.
In the following lecture Śrīla Prabhupāda speaks about differences between women, men and śūdras:
“So this combination, Vedic idea that woman must be under the… They have got three stages of life. First stage under the father, second stage under the husband. Therefore initiation, to the woman, there is no need of, I mean to say, sacred thread, because she’s considered to be the half body of her husband. She’s half-shareholder in everything of the husband; therefore there was no necessity. Even you’ll find in the picture of Rāmacandra and Sītā, Rāmacandra has got sacred thread but Sītā hasn’t got. That is the system. So this is Vedic system, that woman is given the mantra but not the sacred thread. Even she’s born of a brāhmaṇa father, there is no such system. No. In the Bhagavad-gītā you’ll find, strī-śūdra-dvijabandhūnāṁ.
māṁ hi pārtha vyapāśritya ye 'pi syuḥ pāpa-yonayaḥ striyo śūdrā tathā vaiśyās te 'pi yānti parāṁ gatim [Bg. 9.32]
“For… From becoming Kṛṣṇa consciousness there is no, I mean to say, deter, anything that can hamper for becoming Kṛṣṇa conscious. But so far this Vedic system is… And this offering of sacred thread, formerly in the Vedic age it was offered only to the brāhmaṇa, kṣatriya, vaiśya, higher class, not to the śūdrās.
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So at the present moment everyone is śūdrā. Then why the sacred thread is offered? No, the sacred thread is not offered to the śūdrā, it is offered to the highest brāhmaṇa in Kṛṣṇa consciousness. And how? Because in India the caste system is by birth. But that is not recognized. So even one is not born in a brāhmaṇa family, a kṣatriya family, still Sanātana Gosvāmī says that by the process of initiation, any man can become a twice-born brāhmaṇa.” (Initiation Lecture, Boston, May 21, 1968).
So, the distinction was retained—although everyone was “spiritually equal”, still only male disciples received the sacred thread from Śrīla Prabhupāda, while female disciples didn't.
OTHER EXAMPLES OF WOMEN IN THE VEDIC AGE
The time depicted in Rāmāyaṇa is considered to be when the Vedic Age was at its highest point. In the Vālmīki Rāmāyaṇa, we find the following evidence regarding ladies,
sā kṣauma-vasanā hṛṣṭā nityaṁ vrata-parāyaṇā
agniṁ juhoti sma tadā mantravat kṛta-maṅgalā (2.17.10)
And cheerful Kauśalyā, who was dressed in fine silk and was dedicated to her vows, offered a fire sacrifice by uttering mantras to make everything very auspicious.
Commentary to this verse by Govindarāja[28] from the Śrī-sampradāya, written on Lord Veṅkaṭeśvara's order:
juhoti hāvayati. ata eva hāvayantīm iti vakṣyati. brāhmaṇair iti śeṣaḥ.
Translation: “Offered oblations” means that she had others to offer them [on her behalf]. That is why [in the next verse] it is said “hāvayantīm” [Rāma saw her mother as] “offering sacrifice through others.” It means “through the brāhmaṇas”. [End of the translation]
Here is the next verse (2.17.8) where the causative verb hāvayantīm is used:
praviśya ca tadā rāmo mātur antaḥ-puraṃ śubham
dadarśa mātaraṃ tatra hāvayantīṃ hutāśanam
“Then, having entered the auspicious inner chambers of His mother, Rāma saw her there having oblations offered in the sacrifice on her behalf.”
Another commentary by Satya Tīrtha (Madhva-sampradāya):
juhoti sma svayam evājuhot. nanu strīṇāṁ vedādhikārābhāvāt kathaṁ juhotīty uktam iti cen na. daśarathasya vaivasvata manutvena tat-patnyāḥ kausalyāyā mānavītvenottama-strītvād vedādhikāra sambhavāt. “āhur apy uttama-strīṇām adhikāraṁ tu vaidike” ity ādi-smṛteḥ. tad uktam vāmane:
bhaviṣyad antare bhūtvā manur vaivasvato bhavān
tava vaṁśe bhavāmy aṅga rāmo dāśarathiḥ svayam
punar daśaratho bhūtvā tvam evāsi pitā mama
mad-datta piṇḍa-dānena muktis te bhavitā dhruvam iti
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na kevalaṁ svayaṁ juhoti api tu brāhmaṇair apīty āha - hāvayantīti.
Translation: “Juhoti” means that she indeed personally offered oblations. If you say “But women are not qualified to study the Vedas, so how it is said that she offered oblations?” we reply no, it is not so. Because Daśaratha was Vaivasvata Manu, his wife was the wife of Manu, therefore she was in the category of highest ranked women (uttama-strī) and therefore it was possible for her to study the Vedas. The primeval smṛti says: “But it is said that women of the highest rank have the eligibility to study the Vedas.” It is described in the Vāmana-purāṇa:
“You were Vaivasvata Manu. I belong to your dynasty, my dear, as Rāma, son of Daśaratha. Again, having become Daśaratha, you are my father. By my offering of piṇḍa you will surely attain liberation.” 
She did not only offer oblations herself, but also through the brāhmaṇas, that is why the causative word “hāvayantī” is used.
And even Sat-kriyā-sāra-dīpikā, which is a vaiṣṇava-smṛti, does not seem to endorse women uttering mantras in lāja-homa during vivāha—when a bride offers lāja, the priest (or husband) chants mantras:
oṁ iyaṁ nāry-upabrute agnau lājān āvapatnī
dīrghayur astu me patiḥ śataṁ varṣāṇi jīvatvedhantāṁ nau hari bhaktiḥ
svāhā - idam kṛṣṇāya idam na mama
“This woman speaks, while offering lāja to the fire: May my husband be long lived, may he live a hundred years. May our devotion to the Lord flourish.”[29]
Even if we accept that Kauśalya directly offered oblations into the fire, we can safely conclude that this is just another instance of a rule that is not applicable in Kali-yuga (as confirmed by Apastamba above) since we do not find so many examples of this in the śāstra.
THE PATH OF THE TANTRAS
However, the path of the Tantras and Āgamas was open to women and śūdras. The endorsement of this path by Sri Caitanya and his associates is evident from the stark contrast that the following statement shows in its attitude towards the śūdras:
kībā vipra kibā nyāsi śūdra kene naya
yei kṛṣṇa-tattva-vettā sei guru haya (Caitanya-caritāmṛta, Madhya 8.128)
Whether one is a brāhmaṇa, a sannyāsī or a śūdra—regardless of what he is—he can become a spiritual master if he knows the science of Krishna.
Śrīla Prabhupāda makes it evident in his purport on this verse of Caitanya-caritāmṛta that the term 'guru‘ can be applied equally to vartma-pradarśaka, śikṣā and dīkṣā gurus.
However, neither Śrī Caitanya Mahāprabhu nor Śrīla Prabhupāda in his purport say anything about women-gurus—men are mentioned three times - 'vipra', 'nyāsi', 'śūdra', but not 'strī', 'nārī' or 'yoṣit'. So we
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see this as another extrapolation.
THE TANTRAS ARE A BONAFIDE WAY OF WORSHIPING THE LORD
Some vaiṣṇavas cringe upon hearing the word 'tantra‘, associating the term with ritualistic drinking of alcohol and performance of ritualistic sex.
The statement “The Tantras are a bonafide way of worshiping the Lord” is a very general and hence a very bold one, since the word 'tantra' historically is a term usually denoting non-othodox practices like drinking alcohol or performance of ritualistic sex. That's precisely why some vaiṣṇavas cringe upon hearing this word. So without explanation of exactly which tantras are bonafide (Vaiṣṇava-tantras (Sātvata-tantras) as opposed to Śākta-tantras or Śaiva-tantras), the authors risk an unpleasant confusion. This is another example of extrapolating the “allowed” tantras to mean “all” tantras.
In the Śrīmad-bhāgavatam, however, Krishna clarifies the situation:
vaidikas tāntriko miśra iti me tri-vidho makhaḥ
trayāṇām īpsitenaiva vidhinā māṁ samarcaret (11.27.7)
One should carefully worship me by selecting one of the three methods by which I receive sacrifice: Vedic, tāntric, or mixed.
In their commentaries on this verse our ācāryas explain the word 'tāntric' as follows:
Viśvanātha Cakravartī Ṭhākura:
evaṁ tāntrikaḥ gautamīya-tantrādy-uktaḥ
“Tāntrika means procedures described in works such as Gautamīya-tantra”.
[Gautamīya-tantra is a bonafide Vaiṣṇava-tantra; other tantras may be not]
Śrīla Bhaktisiddhānta Sarasvatī Ṭhākura:
“vaidika, pāñcarātrika o miśra-vidhi-sakala bhajanīya vastuke samyag-rūpe pūjā karite samartha haya”
“The Vedic, Pāñcarātrika, and a combination of both, are the three methods to properly worship the Supreme Lord.”
So, the 'tāntric' means “pāñcarātrika” method.
THE PATH OF THE TANTRAS IS MORE PROMINENT IN KALI YUGA
The Śrīmad-bhāgavatam also says:
taṁ tadā puruṣaṁ martyā mahā-rājopalakṣaṇam
yajanti veda-tantrābhyāṁ paraṁ jijñāsavo nṛpa
iti dvāpara urv īśa stuvanti jagad-īśvaram
nānā-tantra-vidhānena kalāv api tathā śṛṇu (11.5.28, 30)
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My dear King, in Dvāpara-yuga, men who desire to know the Supreme Personality of Godhead, who is the supreme enjoyer, worship him in the mood of honoring a great king, following the prescriptions of both the Vedas and tantras. O King, in this way people in Dvāpara-yuga glorified the Lord of the universe. In Kali-yuga also, people worship the Supreme Personality of Godhead by following various regulations of the tantras (revealed scriptures).
Srila Sridhara Swami says in his commentary on this verse:
nānā-tantra-vidhāneneti kalau tantra-mārgasya prādhānyaṁ darśayati
By the word nānā-tantra-vidhānena in the verse, the predominance of the path of tantras [over the Vedic Path] is shown in Kali-yuga.
Again, in his commentary on the verse 11.5.28 Śrīla Bhaktisiddhānta Sarasvatī Ṭhākura explains that the “tantra” here means specifically the “Pañcarātra”:
'veda-tantra' – śabde vaidika o tāntrika arthāt āgama vā sātvata pāñcarātra-vihita mārge
“The word veda-tantra means the path of the Vedas and the Tantras, or Āgamas – the Sātvata Pañcarātras”.
This is perfectly confirmed by the verses following directly after 11.5.28 quoted above:
namas te vāsudevāya namaḥ saṅkarṣaṇāya ca
pradyumnāyāniruddhāya tubhyaṁ bhagavate namaḥ
nārāyaṇāya ṛṣaye puruṣāya mahātmane
viśveśvarāya viśvāya sarva-bhūtātmane namaḥ (11.5.29-30)
“Obeisances to You, O Supreme Lord Vāsudeva, and to Your forms of Saṅkarṣaṇa, Pradyumna and Aniruddha. O Supreme Personality of Godhead, all obeisances unto You. O Lord Nārāyaṇa Ṛṣi, O creator of the universe, best of personalities, master of this cosmos and original form of the universe, O Supersoul of all created entities, all homage unto You.”
This catur-vyūha concept described here is a prominent feature of the Pañcarātra literature, but not of the Śākta-tantras.
Thus the word 'tantra' in a title doesn't automatically make a book bonafide.
THE TANTRAS ALLOW FEMALE GURUS
Śākta-tantras (like Rudra-yāmala) surely do, but, again, are they authoritative for the vaiṣṇavas?
An interesting logic—the authors want us to presume that all tantras are bonafide and since some of them (Śākta-tantras) allow female gurus—we have accept the conclusion as bonafide.
The Rūdra-yāmala-tantra (2.32) says in regard to female gurus:
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* Śrīla Bhaktivinoda Ṭhākura writes in his “Apasampradāyera-svarūpa”:
“There are two kinds of smṛti-śāstra:
1) spiritual, or sātvata smṛtis;
2) material, moral or fruitive work oriented smṛtis.
Satvata smrtis include: Sri Bharadvaja-samhita (included in Narada-pancaratra), Brhat-samhita, Visnu-samuccaya, Vaikhanasa-samhita, the Agama-pramanyam compiled by sage Alabandaru, the Sadacara-smrti compiled by sage Purnaprajna, the Krsnamrta-maharnava, the Smrty-artha-sagara by Chadari Nrsimhacarya, the Prameyamala by Viraraghava, the Prayoga-candrika, the Vaisnava-dharma-sura-druma-manjari by Samkarsana Saranadeva, the Smrti-ratnakara by Vitthalacarya, the Sri Hari-bhakti-vilasa by Srila Gopala Bhatta Gosvami Prabhu, the Sri Sat-kriya-sara-dipika and the Samskara-candrika-paddhati by Sri Dhyana Candra.”
§ The Kaulas are famously described in the following verse:
antaḥ śāktа̄ḥ bahiḥ śaivа̄ḥ
sabhāyāṁ vaiṣṇavo matа̄ḥ
nānā-rūpa-dharāḥ kaulā
sādhvī caiva sadācārā guru-bhaktā jitendriyā
sarva-mantrārtha-sarvajñā sadhavā pūjane ratā
guru-yogyā bhaved eṣā vidhavāṁ parivarjayet
A saintly and righteous lady who is dedicated to her guru, a knower of all the mantras, all knowledgeable and who is constantly engaged in worship of the Lord, is eligible to become guru, except for a vidhavā, a lady whose husband has passed away.
From this verse it seems that the preferred candidates for women gurus are those who are duly married. However, the same book says that even the vidhavās are allowed if the mantra is a transcendental mantra and not a material one:
siddha-mantro yadi bhavet gṛhṇīyād vidhavā-mukhāt (2.113)
If the mantra is a siddha-mantra or a transcendental mantra, it can be accepted from a vidhavā.
Just to give another interesting example—before the verse guru-yogyā bhaved eṣā vidhavāṁ parivarjayet quoted above there is another interesting verse:
ananta-guṇa-sampannā rudratva-dāyinī priyā
guru-rūpā mukti-dātrī śiva-jñāna-nirūpiṇi
“She [such guru] is endowed with all good qualities, she bestows the position of Rudra and is very dear. She is guru-like in appearance, she is the giver of liberation and she explains the Śiva wisdom.” (2.109)[30] [emphasis added].
We are repeatedly told by our ācāryas that tantras acceptable for the vaiṣṇavas (sātvatas) are the pañcarātras (such as Nārada-pañcarātra, Hayaśīrṣa-pañcarātra etc*). The problem here is that Rudra-yāmala-tantra is by no means a sātvata-tantra (pañcarātra). The contents of the Rūdra-yāmala-uttara-tantra clearly shows that it is not at all a vaiṣṇava-tantra, but a śākta-tantra associated with the tantric “Kashmiri School of Kaula tradition§” (see Muller-Ortega, Paul (1989), The Triadic Heart of Siva, Albany: State University of New York
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vicaranti mahi-tale
“Inwardly śāktas, outwordly śaivas, and in the society nominally vaiṣṇavas, the Kaulas assuming various forms traverse the earth.” (Śyāma-rahasya-tantra and Kaulāvali-nīrṇaya, 10.85).
This description is also quoted by Śrīla Prabhupāda in his purpot to Caitanya-caritāmṛta, Madhya, 3.85: “In Khaḍadaha, sometimes people misunderstood Nityānanda Prabhu to belong to the śākta-sampradāya, whose philosophy is antaḥ śāktaḥ bahiḥ śaivaḥ sabhāyāṁ vaiṣṇavo mataḥ. According to the śākta-sampradāya, a person called kaulāvadhūta thinks materially while externally appearing to be a great devotee of Lord Śiva. When such a person is in an assembly of Vaiṣṇavas, he appears like a Vaiṣṇava. Actually Nityānanda Prabhu did not belong to such a community. Nityānanda Prabhu was always a brahmacārī of a sannyāsī of the vaidika order. Actually He was a paramahaṁsa. Sometimes He is accepted to be a disciple of Lakṣmīpati Tīrtha. If He is so accepted, Nityānanda Prabhu belonged to the Mādhva-sampradāya. He did not belong to the tāntrika-sampradāya of Bengal.”
Here we also see that Śrīla Prabhupāda, following his spiritual master's commentary, uses the word “vaidika” to contrast the “tāntrika” conception that people had about Lord Nityānanda.
* A work named “Rudra-yāmala” is also quoted in: Jīva Gosvāmī's Rādhā-Kṛṣṇārcana-dīpikā, Viśvanātha Cakravartī's commentary on Ujjvala-nīlamaṇi, Gopāla Bhaṭṭa Gosvāmī's Sat-kriyā-sāra-dīpikā, Dhyānacandra Gosvāmī's Gaura-govindārcana-smaraṇa-paddhati, Rādhā-Kṛṣṇa Gosvāmī's Sādhana-dīpikā etc. The striking feature of all these quotations is that they all speak about pure bhakti and about the glories of Kṛṣna, Rādhā, gopīs and Vṛndāvana—but all this is conspicuously absent from the Rudra-yāmala-uttara-tantra under discussion.
Press, p.57-58) and hence quoting it does not prove anything.
Here is what scholars have to say about Rudra-yāmala-tantra:
“The Rudrayāmala is perhaps the most mysterious of all Yāmalas. It is encountered everywhere, yet always vanishes after closer inspection. It is even uncertain if an original Rudrayāmala ever existed, despite the fact that the title figures in all old lists of Yāmalas. More than fifty texts adorn themselves with this generic designation beside their own title (type: "text X from the Rudrayāmala"), but a "Rudrayāmala" without more is not found or clearly apocryphal. The practice must have set in early; the first instance is perhaps furnished by the Parātriṃśikā and its example was followed by the Vijñāna-bhairava which calls itself "Rudrayāmalīya". Other works joined these worthy predecessors, so that the Rudrayāmala developed into the foremost locus of ascription in Hindu Tantric literature.” (T.Goudriaan and S.Gupta, Hindu Tantrik and Śākta Literature, Wiesbaden, 1981, p.47).
So, we leave it to the scholars of the tradition to decide:

whether this Rudra-yāmala-Uttara-tantra is a completely different tantra from that Rūdra-yāmala which is only once quoted in the Hari-bhakti-vilāsa (2.28) in relation to the exceptions in the time for initiation*;

or whether there are several different tantras with the same name (or several tantras belongling to Rudra-yāmala and Uttara-tantra being only one of them) (The most likely option in our humble opinion); 

or whether it is the same tantra which was considerably interpolated later (which is very unlikely);

or if there is that verse quoted in Hari-bhakti-vilāsa in the modern versions of Rudra-yāmala-tantra;

or whether this is just another example of the following consideration, that was also quoted by authors themselves: “It is Śrīla Bhaktisiddhānta Sarasvatī Gosvāmī’s opinion, however, that to follow the Hari-bhakti-vilāsa strictly is to actually follow the Vaiṣṇava rituals in perfect order. He

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claims that the smārta-samāja, which is strictly followed by caste brāhmaṇas, has influenced portions that Gopāla Bhaṭṭa Gosvāmī collected from the original Hari-bhakti-vilāsa. It is therefore very difficult to find out Vaiṣṇava directions from the book of Gopāla Bhaṭṭa Gosvāmī.” (Caitanya-caritāmṛta, 2.1.35, purport)

Whatever it may be, but from the contents of the Rudra-yāmala-tantra that the paper refers to it is clear that it is not applicable for the vaiṣṇavas, because among many other things that Rudra-yāmala-tantra describes are:

Three types of sādhaka's nature - paśu (animal), vīra (heroic) and divya (divine) - a concept typical to the śākta-tantras (verse 2.6 and many other places). The description of the paśu-bhāva (animal attitude) begins in the same 2nd chapter quotes from which were used in the paper.

Kuṇḍalinī (in many places—e.g. 22.14) and 108 names of kuṇḍalinī—36th Chapter.

The famous tantric “hamsa mantra” (reversed “so'ham” - “I am him”) 22.91-108.

The abominable “śava-sādhana” (a particular tantric practice with a dead body)—in the 24th chapter.

The notorious pañca-mākāra practice (with meat, wine, fish, sex and mudras)—26.129-246 (where it is also stated “māṁsāśī sa bhaved eva”—“such sādhaka should become meat-eater”)

So we would rather not rely on this suspicious quote from such a Tantra.
And besides that, the paper unfortunately does not provide a single quote from any vaiṣṇava-tantra (Pañcarātra) that allows women to become gurus. Of course, Pañcarātra allows anyone to receive dīkṣā—either woman, śūdra, mleccha etc., for example:
A part of the Nārada-pañcarātra called Bhāradvāja-saṁhitā[31] , which has been referred to by many ācāryas in their works (e.g. Śrīla Prabhupada in his purport to the Śrīmad-bhāgavatam (4.31.10), Śrīla Bhaktisidhānta Sarasvatī Ṭhākura in his commentary on Caitanya-bhāgavata (1.8.7), Śrīla Bhaktivinoda Ṭhākura in his article called “Apa-sampradāyera-svarūpa” and Gopāla Bhaṭṭa Gosvāmī in his Sat-kriyā-sāra-dīpikā) says:
prāptum icchan parāṁ siddhiṁ janaḥ sarvo 'py akiñcanaḥ
śraddhayā parayā yukto hariṁ śaraṇam āśrayet
All those materially bereft people who desire to attain the highest perfection of life should take shelter at Lord Hari with great faith.
na jāti-bhedaṁ na kulaṁ na liṅgaṁ na guṇa-kriyāḥ
na deśa-kālau nāvasthāṁ yogo hy ayam apekṣate
This yoga (or prapatti, self-surrender) does not depend on caste distinctions, nor on the birth in particular family, nor on the gender (or the external symbols of different aśramas), nor on the qualities or activities of the candidates. It also does not depend on the time, place and circumstances.
brahma-kṣatra-viśaḥ-śūdrāḥ striyaś cāntarajās tathā
sarva eva prapadyeran sarva-dhātāram acyutam
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Brāhmaṇas, kṣatriyas, vaiśyas, śūdras, women and even outcastes—all of them undoubtedly can attain Lord Acyuta, who is the supporter of everyone. (Bhāradvāja-saṁhitā, 1.13-15)
Bhagavad-gītā (9.32) and Śrīmad-bhāgavatam (2.7.46) make similar famous statements.
However, the same Bhāradvāja-saṁhitā prohibits women to give dīkṣā:
na jātu mantra-dā nārī na śūdro nāntarodbhavaḥ
nābhiśasto na patitaḥ kāma-kāmo 'py akāminaḥ
A woman should never become initiating guru, and also a śūdra, a person born from an improperly mixed marriage, a very sinful and defamed person, a fallen person or one who is full of material desires. (1.42)
From this list we have the apavāda (exception) for the śūdra—on the basis of Lord Caitanya's statement “kībā vipra kibā nyāsi śūdra kene naya”, so we still have to find another proof for female initiating gurus.
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BIBLIOGRAPHY
[1] Patrick Olivelle (ed.), The Early Upanisads, Annotated Text and Translation, Oxford University Press, 1998, p.157.
[2] Atharva-veda-saṁhitā with the commentary of Sāyaṇācārya, Jawaji Dadaji, Mumbai, 1897, pp.113-114.
[3] Ṛgveda-saṁhitā with the commentary of Sāyaṇācārya, Vaidika Samsodhana Mandala, Poona, 1946, Vol.4, p.846.
[4] The Hymns of the Rigveda, translated with the popular commentary by R.T.H. Griffith, Second Edition, Vol.2, Benares, 1897, p.596.
[5] We used the same edition as the authors of the paper - Vīramitrodaya, Samskāra Prakāśa, of Mahāmahopādhyāya Paṇḍita Mitra Miśra, Edited by P.N. Sharma, Chowkhamba Sanskrit Series, Printed by Jai Krishna Das Gupta, Vidya Vilas Press, Benares. 1919.
[6] Smṛti-candrikā by Devaṇa Bhaṭṭa, Saṁskāra-kāṇḍa and Āhnika-kaṇḍa, edited by L.Shrinivasacharya, Mysore, 1914., vol.1, p.29.
[7] Buhler, George. The sacred laws of the Aryas as taught in the schools of Apastamba and Gautama, Oxford, 1879, Sacred Books of the East, Vol.2, p.138.
[8] The Critical Edition of the Mahabharata, Vol.1, The Adiparvan, Poona, 1933, p.500.
[9] Buhler, George. Apastamba's aphorisms on the Sacred Law of the Hindus, 1932, p.72.
[10] Buhler, George. The sacred laws of the Aryas as taught in the schools of Apastamba and Gautama, Oxford, 1879, Sacred Books of the East, Vol.2, p.131.
[11] - Sanskrit text of the sūtras and the commentary is taken from: “Mīmānsādarśana, with the commentary of Sabara Swami, edited by Pandita Ratna Gopala Bhatta, Benares, 1910”;

English translation is based on “Shabara-bhashya, Translated into English by Ganganatha Jha”, Baroda ,1934, Vol.2, pp.976-994.


[12] Buhler, George. Apastamba's aphorisms on the Sacred Law of the Hindus, 1932, p.76.
[13] Buhler, George. The sacred laws of the Aryas as taught in the schools of Apastamba and Gautama,
Oxford, 1879, Sacred Books of the East, Vol.2, p.
[14] Apastamba-grihya-sutra with the commentary of Sudarsanacharya, edited by Mahadeva Sastri, Mysore, 1893, p.132.
[15] The Grhya-Sutras, Rules Of Vedic Domestic Ceremonies, translated by Hermann Oldenberg, Part.II Gobhila, Hiranyakesin, Apastamba, Sacred Books of the East, vol.30, Oxford, 1892, p.267.
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[16] - Sanskrit is taken from: Śrī Vāsiṣṭha-dharma-śāstram, edited by A.Fuhrer, Poona, 1930, p.61;
- English translation is from: Patrick Olivelle, Dharmasūtras: The Law Codes of Āpastamba, Gautama, Baudhāyana and Vasiṣṭha, Oxford University Press, 1999, p.305
[17] Hari-nāmāmṛta-vyākaraṇa, unpublished manuscript.
[18] The Veda Of The Black Yajus School Entitled Taittiriya Sanhita, translated from the original Sanskrit prose and verse by Arthur Berriedale Keith, Cambridge, Massachusetts, 1914.
[19] In this section about Ṛgveda:
- Sanskrit text is taken from “Ṛgveda-saṁhitā with the commentary of Sāyaṇācārya, Vaidika Samsodhana Mandala, Poona, in 4 Vols, 1936-1946”
- English translation is from The Hymns of the Rigveda, translated with the popular commentary by R.T.H. Griffith, Second Edition, Benares, 1897.
[20] The Satapatha-Brahmana, translated by J.Eggeling, Oxford, 1900, Sacred Books of the East, Vol.44, p.300.
[21] Parāśara-dharma-saṁhitā with the commentary of Sāyaṇa Mādhavācārya, edited by V.S. Islampurkar, in 6 volumes, Mumbai, 1893-1919.
[22] Bhaktisiddhnta Saraswati Thakur, Brahmana and Vaishnava, translated by Bhumipati dasa, Vrajraja Press, 1999.
[23] V.S. Apte, The Practical Sanskrit-English Dictionary, Motilal Banarsidass, Delhi, 2022 Samvat (corresponding to 1965 AD), p.44
[24] The Critical Edition of the Viṣṇupurāṇam, edited by M. M. Pathak, in 2 vols., Vadodara: Oriental Institute, 1997, 1999.
[25] The sacred laws of the Aryas as taught in the schools of Apastamba, Gautama, Vasishtha and Baudhayana, translated by G.Buhler, part 2: Vasishtha and Baudhayana, Oxford, 1882, Sacred Books of the East, Vol.14, pp.110-111.
[26] P.Olivelle, Dharmasutras: The Law Codes of Apastamba, Gautama, Baudhayana, and Vasistha (Sources on ancient Hindu law), Oxford University Press, 1999, p.307.
[27] Satkriyā-sāra-dīpikā o Saṁskāra-dīpikā, Śrī Gauḍīya Vedānta Samiti, Navadvīpa, 2012.
[28] Śrīmad Vālmīki Rāmāyaṇa, A Critical Edition, With the commentary of Śrī Govindarāja and Extracts from many other commentaries and readings, Nirnaya-sagar Press, Bombay, 1911, Vol.2, p.94.
[29] Sat Kriya Sara Dipika by Shrila Gopala Bhatta Gosvami, The Bhaktivedanta Academy, Mayapur, 1999.
[30] Rūdra-yāmalam Uttara-tantram, edited by Jibananda Vidyasagara, Kolkata, 1937.

[31] Nārada-pañcarātra (Bhāradvāja-saṁhitā), with the commentary of Sarayū-prasāda Miśra, Śrī Veṅkaṭeśvara Steam Press, Mumbai, 1905.

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