The Dharma Sastras are texts in Hinduism that are concerned with the legal precedent or law that is in relation to dharma (Rodrigues, 535). Dharma as it relates to the Dharma Sastra’s acts as a guide to what a Hindu must do in their life to fulfil their dharmic duty. In relation to religious texts for Hindu’s the Dharma Sastras are considered smrti [all texts containing traditions] not sruti [divinely heard or from the gods] an example of these are the Vedas (Banerji, 1). As the Dharma Sastras are smrti which are of human authorship they are not as revered as are the main sruti texts of the Hindu religion.

The exact origin of the Dharma Sastras is not known but it is believed that the Dharma Sastras can be traced back to Vedic times. The Dharma Sastras were believed to be written because the Dharma Sutras[texts that contained dharmic law and were the basis for the Dharma Sastras] were antiquated and a new text was needed to address the increasingly complex needs of society. Therefore, the Dharma Sastras were needed to explain the more complex matters that were arising in this new era (Banerji, 4-5).

Just as the Dharma Sutras contains many works, the Dharma Sastras do as well, with the main works being of Manu, Yajnvalka, Parasara, Katyayana, and Narada, [these are all different Dharma Sastra writers however Manu was most extensive and all had similar teachings]; however, these are just a few of the works that are considered Dharma Sastras, and there are many more examples. This paper will mention the main two Dharma Sastras, which are regarded highly as important smrti writings and legal codices of ancient India. The two works are the works of Manu and Yajnavalka. Where Manu`s works contains information on acara, prayascitta, vyavahara, and rajadharma. Where the Yajnavalka only comments on three of these which are the acara, prayascitta, and, vyavahara (Banerji 30-35)

The Manu Smrti is a name used for the Laws of Manu. It is considered the most important of the Dharma Sastras [the composition of Manu Smrti according to B. C. Kane to fall somewhere in between second century BC and second century AD](Banerji, 31). The Laws of Manu are composed of a manuscript which is divided into twelve adhyayas [lessons or chapters]. According to Patrick Olivelle these twelve adhyayas is an “old version” as all of the commentaries on it Manu’s works follow that there is the twelve adhyayas. However, Olivelle suggests that it is not the original breakup of the adhyayas of the Laws of Manu, and further suggests that there was a possibility of more at one time before the commentaries were written (Olivelle, 7). This version is also considered to contain two thousand six hundred ninety four verses. However, it is not known who composed the work; there are several different opinions concerning authorship, such as those who believe that Manu was a mythical being; others believe that it arose from a school propounded by a sage named Manu (Banerji, 31). In P. V. Kane’s History of the Dharmasastras, he states that myth says Manu is possibly the father of the human race and a semi-divine sage that received the laws and regulations from God (Kane, 307 vol. 1). This causes confusion as to who was the actual author of the work. However, the work itself says “Brahma formulated this sastra, and taught it to Manu. (Banerji, 31) ” This Dharma Sastra has some contradicting statements such as allowing brahmins to take a sudra wife in one adhyaya and forbidding it in another adhyaya. This brings forth an assumption that this Dharma Sastra was possibly brought through three different stages of its development in its writing. While, this is thought because of the contradictions may indicate the works could have been written by more than one hand.  Some scholars disagree that this is the case.  It is said that the Laws of Manu is to the most commented on of all the smrti literature composed (Banerji, 30-34). It is also considered to be the most authoritative work of all the Dharma Sastras and is commented in the Yajnavalka by saying “that smrti which runs counter to Manu is not commended (Banerji, 33)” and “whatever Manu said is medicine. (Banerji, 33)” Showing that this Dharma Sastra is the most influential work, it is even stated in other versions of the Dharma Sastras as other authors of the Dharma Sastras recognize it as the most .

The Yajnavalka Smrti [the second most important Dharma Sastra] which was composed by Yajnavalka himself is also very important version of the Dharma Sastra. It is believed to have been written between first century BCE and third century CE.  This version is important because it brings order to three of the subjects that are touched in the Laws of Manu. The three topics that Yajnavalka brings order to is acara, vyavahara, and prayascitta. Yajnavalka lays these out in an order so that they are to be easily understood. The most famous portion of this Dharma Sastra is its section on the vyavahana which concerns itself with secular law. A subsection in the vyavahana has actually given rise to two different schools of law, the Mitaksara which is law in all of India except Bengal, and the Dayabhaga which is the law in Bengal. There have been a few changes made to the Yajnavalka, between eight hundred and eleven hundred CE and other then these few changes the text is believed to be intact since seven hundred CE (Banerji, 34-35)

I will now touch on the subjects that are talked about in the Dharma Sastras, these topics being acara, vyavahara, prayascitta, and rajadharma. Acara [customary laws] in the Dharma Sastras is concerned with the practice of dharma in the everyday life of a Hindu and the ways in which they must live in order to be a dharmic Hindu (Davis, 814). This meaning that acara was concerned with ensuring that you could have a good dharmic life. To ensure that a person has a good dharmic life they must follow the samskaras [life cycle rites that Hindus participate in(Rodrigues, 562)] . This is mostly for brahmins who are to lead a life devoted to the dharma. These samskaras are there to help these brahmins remove their taint and sin that they inherit from their parents. In the acara concerning samskaras there are certain rituals that are only reserved for the twice-born castes brahmin, ksatriya, and vaisyas. Within the twice-born casts, only the males are allowed to have Vedic mantras said, however, in the case of marriage Vedic mantras are uttered for the females of twice-born families. Sudras are only allowed to perform samskaras not reserved for the twice-born. However it is now thought that most of the samskaras are now considered obsolete. Marriage it is not seen as much as a samskara but more of a contract (banerji, 77-81). An example of acara is its provisions in the Laws of Manu regarding bride’s price, selection of a bride, and types of marriage, just to name a few that are concerned with the acara.

Vyavahara [civil and criminal law] is concerned with disputes of law in the sense that western society thinks of law. It contains both civil and criminal law that we in the western world (Banerji, 157). According to the Laws of Manu there are eighteen different disputes. To name a few there is: rnadana which is non-repayment of debt, strisamgrahana which is the molestation and unlawful sexual union of women, and samahvaya which is animal-betting. This is showing that vyavahara concerns itself with the actual laws of the Hindu society which is part of their dharmic responsibility. For a person to follow dharma they must follow these laws because if you break these laws you are not fulfilling your dharmic duty and therefore not fulfilling your responsibilities to dharma. When you look at Hindu laws it is shown that  a similar code covers similar topics as our own laws such as judicial proceedings, evidence, possession and ownership, and crime and punishment (Banerji, 157-167). The Laws of Manu shows examples of what to do with criminal code such as theft and thieves in chapter eight which includes others crimes such as violence and the code also includes how the justice system is to function and a range of different criminal charges (Olivelle, 167-189).

Prayascitta [penance or washing away ones sins] is concerned with the penance of a sinner. It is the washing off of their sin where they make amends for their crimes against dharma. Prayascitta is meant to be used to avert the sinners fall into hell and allows for the sinner to be acceptable for social interaction in that he can partake in social activities within the society. However, prayascitta only makes the sinner acceptable for social interaction within society if they did not intentionally sin. If the person intentionally commits a sinful deed they can avert from falling into hell but cannot gain back their right for social interaction within regular society (Banerji, 90-92). The prayascitta is the way that a Hindu is punished for their wrongdoing. Just as someone in western society is given a jail sentence for a crime to pay penance for his/her wrongdoing; prayascitta to a Hindu is in a sense there “jail sentence” to make amends for their wrongdoing as the jail sentence is to the westerner. Examples of this would be punishments for people who breach Hindu law such as punishments for thieves that is found in chapter eight of Manu’s code of law (Olivelle, 184)

In regards to the last section of Laws of Manu; the section raja dharma concerns itself with the kingly dharma. It is concerned with how a King must live and it contains information on where a king must live and how he must protect himself. It also includes information on how he is to receive council from his ministers; who to have as ambassadors, political expedients’, and other topics that are needed for a king to do their duty (Banerji, 92-100).

These four topics are what make up most of the Dharma Sastras. These are guides for the Hindus to follow in their life. Especially brahmins as they are expected to lead a dharmic life. With these codes they are able to sustain a society that is prosperous and cohesive.

The Dharma Sastras discusses issues from how to live dharmically to what will happen if the codes of your dharma are not followed. It teaches the Hindus about how they must live in their everyday life and shows what are expected of them in their life. It is seen that the Dharma Sastras are also connected to other aspects of the Hindu’s life such as the Arthasastras as they are related in what they teach regarding one’s life duties (Banerji, 6-7). We also see that the Dharma Sastras are related to the epics, in that the epics are seen as the “sources of dharma (Banerji, 7).” The Mahabharata contains many matters that are in the Dharma Sastras so one could think that it is a possibility that the epics are a way of teaching the Hindu’s on how to live there life in an easily understandable way through the narrative. The Dharma Sastras are books that help with everyday life for every Hindu and are needed to ensure that there dharmic duties are fulfilled. These texts are needed for Hindus culture because they make up what a Hindu is and what a Hindu does, showing them how in their lives they can attain their ultimate dharmic goal eventually through living a life of dharma and attaining moksa [liberation from the worldly state].

References and Further Readings

Rodrigues, Hillary (2006) Hinduism the eBook an Online introduction. Journal of Buddhist Ethics online Books.

Olivelle, Patrick (2005) Manu’s Code of Law A Critical Edition and Translation of the Manava-Dharmasastra. New York: Oxford University Press.

Banerji, S.C.(1999) A Brief History of Dharmasastra.New Delhi: Abhinav Publications.

Kane, Pandurang (1968) History of Dharmasatras vol.1, 4. Poona: Bhandarkar Oriental Research Institute.

Davis, Donald R. (2004) Journal of Indian Philosophy. 32:5-6:p.813-830

Related Topics:

• Dharma Sutras
• Laws of Manu
• Yajnavalka Smrti
• Mahabharata
• Acara
• Prayascitta
• Vyabahara
• Rajadharma
• Artha Sastras

Related websites:

• http://hinduism.iskcon.com/tradition/1112.htm
• http://www.hinduwebsite.com/sacredscripts/hinduism/dharma/dharma_index.asp
• http://www.sacred-texts.com/hin/manu.htm
• http://www.dlshq.org/saints/yajnavalkya.htm

Article written by: Tony Slezina (April 2010) who is solely responsible for its contents.

The Laws of Manu are one of the three major Dharma Sastras whose authorship in attributed to Manu, a Hindu Lawmaker (Neufeldt 144; Kumar 207). The text is also known as Manusmrti or Manavadharmasastra and is often referred to as simply Manu. The Laws of Manu are comprehensive set of codices that outline dharmic practices; many scholars refer to them as legal codices (Monius 334). This particular text is widely used by orthodox Hindus as instruct their day to day lives. This practice became even more wide spread after the British came into power in India as the Laws of Manu were implemented at a state level as a way of handling legal issues with the Hindu population (Mitra, 78).

The Laws of Manu have often been criticized as it appears to serve at continuing to propagate inequality within Hindu Society. This is perhaps the case with some practices. However it is important to recognise that the text also has its strengths. Mitra argues throughout her piece Human Rights in Hinduism that the practice of dharma, which is the focus of the Laws of Manu, focuses on justice and thus it does in fact consider the rights of individuals by prescribing dharmic practices. The text outlines the ways in which individuals should protect their families and conduct themselves in public to outline a properly functioning Hindu society.

Like many religious texts, one must consider that interpretations of the verses contained within the Laws of Manu are simply that, interpretations. Different groups and individuals will focus their attention on a particular section of the Manusmirti while completely ignoring others that may contradict their viewpoint. This is particularly present when considering the treatment of women in Hinduism.

Kumar argues throughout his article Manu: The Meaning of Svatantrya and Its Implications for Women’s Freedom that many of the codices in The Laws of Manu itself are actually put in place to protect women. Unfortunately, throughout history women have been particularly vulnerable to rape and other forms of attack and thus, Manu devoted much of his ninth chapter to the proper treatment of women within one’s family (Buhler). Kumar also points out that there are only two main areas where Manu prescribed the control of women’s actions: “… (1) attachments to worldly or sensual objects and (2) sexual relationships with men of inferior classes.” (Kumar, 213). Despite this, Kumar does not deny that in practice the Laws of Manu have also caused the grave mistreatment of Hindu women as well. If one observes verses 147 through 149 of chapter five of the Laws of Manu, it is noted that Manu also prescribed that women should never do any activity independently or try to separate herself from her male family members (Buhler). This may be one explanation for why the advancement of women in the workforce in India has been so difficult. By attempting to independently contribute the household or to support oneself as women would imply that you are directly disobeying the religious doctrine.

The only apparent time that a woman obtains any real power is when she becomes the senior married woman in a household. It is then that other women are expected to turn to her. However even this status has its limits. According to the Manusmrti the wife must still obey her male relatives, which in this case would mean chiefly her husband. So what does a woman do when her husband dies? If a Hindu woman is lucky she will have other male relatives who will care for her, in particular her sons.

A husband is a Hindu woman’s main support explains Wadley (92). Once a woman becomes a widow not only is she viewed as a burden economically, but due to scriptures (for example Laws of Manu chapter 3, verse 57) they are also viewed as a liability. If a woman does not have a son to look after her after her husband’s death a woman is almost guaranteed to suffer many hardships. Especially in the lower classes women often have difficulty supporting themselves as Manu does not encourage an independent woman. Some orthodox Hindus go so far as to argue that a widow is half dead herself as her husband was half of her being (Wadley 105). This leads to even further harsh treatment as there is a sense of becoming untouchable. Chapter three of the Laws of Manu touches on this at several points. When discussing who should not be invited to or served food at the ceremony for the dead several references are made to sons of widows and remarried women and men who have taken their older brother’s place; i.e. a younger brother who has married his deceased brother’s widow (Doniger 57-62). It is quite clear that in the context of the ceremony of dead, individuals associated with widows are not to be thought of highly.

Doniger (xliv) points out that the Laws of Manu appears full of contradictions, but really is a series of rules and a list of their exceptions. Part of the text actually does focus on the good treatment of women, as is seen in chapter 3 verses 51 through 63. These verses focus both on the necessity of women’s happiness to a household’s happiness and the proper practice for arranging a daughter’s marriage. In my opinion, verse 51(Doniger 48) shows a respect for women as people because it states, “No learned father should take a bride-price for his daughter, no matter how small, for a man who, out of greed, exacts a bride-price would be selling his child like a pimp.” Throughout the text we see verses like this and then others which appear to knock women down to an inferior level. However, it is important to note that the majority of verses which hold women in a negative light are context specific, and thus it is not the text that has caused injustice to women, but its use outside the context which were outlined.
The Laws of Manu are deeply entrenched in Hindu society. This particular Dharma Sastra is perhaps the most influential religious-legal scripture in existence. Its far reaching influence has been both beneficial and troublesome throughout Hindu history and certainly cannot be discounted within the tradition. However, it is also important to note that the text was compiled between the second century B.C.E. and the second century C.E. thus policies that were once useful and protective must be taken within their historical context and adjusted to the different eras they are used in, in order to prevent undue discrimination and maltreatment.

REFERENCES AND OTHER FURTHER READING

Buhler, Georg (1886) The Laws of Manu Sacred Text of the East. Volume 25.Gloucestershire: Clarendon Press.

Doniger, Wendy (1991) The Laws of Manu. Toronto: Penguin Books Canada.

Kumar, Sanjay (2006) “Manu: The Meaning of Svatantrya and Its Implications for Women’s Freedom.” The Journal of Religious Studies, 34, 207-223

Mitra, Kana (1982) “Human Rights in Hinduism.” Journal of Ecumenical Studies, 19, 77-84

Monius, Anne E. (2005) “Origin of Hindu Ethics.” In The Blackwell Companion to Religious Ethics (William Schweiker, Editor) Oxford: Blackwell Publishing

Neufeldt, Ronald W. (2001) “Justice in Hinduism.” In Spiritual Roots of Restorative Justice (Michael L. Hadley, Editor) Albany: State University of Albany Press

Olivelle, Patrick (2004) “Manu and the Arthasastra A Study in Sastric Intertextuality.” Journal of Indian Philosophy, 32, 281-291

Sharma, Pajendra Nath (1980) Ancient India According to Manu. Delhi: Nag Publishers

Wadley, Susan (1995) “No Longer a Wife: Widows in Rural North India.” In The Margins of Hindu Marriage (Lindsey Harlan & Paul B. Cartwright, Editors) New York: Oxford University Press.

Related Topics for Further Investigation

Hindu Widows

Untouchables

Ancient India

Dharma Sastra

Arthasastra

Religion in Society

Noteworthy Website Related to Topic

http://www.sacred-texts.com

http://www.happyvalues.com/ebooks/he20061432/HinduismEbook0509.pdf

Written by Rachelle Lamoureux (Spring 2008) who is solely responsible for its content.

One might wonder what exactly “Dharma Sutra” means and how it came about. It is a blend of the two components ‘dharma’ and ‘sutra’. Therefore this blend obviously means ‘sutras’ dealing with ‘dharma’ (Banerji 1). It is hard to define Dharma itself as it could be interpreted in many ways. However, it is often understood as religion or moral code (Sekhar 1).Hence, I would say that Dharma Sutras deal with directions about our domestic, social and religious lives.

The origin of Dharma Sutra, just like the many other ancient Indian literature, is veiled in shadows. The Dharma Sutra is part of the Kalpa Sutras which is derived from the Vedas. Therefore from this significance we can say that Dharma Sutra is also written during the Vedic age. The Vedas have two different aspects, speculative and ritualistic (Banerji 7). Much later into the Vedic age, literature becomes more focus on rites and rituals. As the civilization was growing, this led to the preparation for shorter and easier manuals of these ritualistic works. In the process of trying to do this, the Kalpa Sutras were composed. To distinguish heterogeneous matters within the Kalpa Sutras, it was classified into three distinct classes. These were the Śrauta which deals purely with Vedic rites, Grhya which deals with domestic rites performed before the domestic fire and Dharma which deals principally with the rules of conduct and Vyavahāra.

People tend to overlap and think that Grhya Sutra and Dharma Sutra deal with the same idea. However, they do not deal with the same idea; instead they have a close comparison of the contents within these sutras. Grhya Sutra deals absolutely with just the domestic rites and the procedure of how one is supposed to go about doing the rites. Dharma Sutra not only deals on the ‘law’ or righteousness but also on the broader stand about the conduct of men, secular law (Vyavahāra) and duties of the king (rāja–dharma). Even then still, people wonder “What is the reason of the overlapping of the contents of these two types of works in respect of certain rites, e.g. upanayana, vivāha, etc (Banerji 10)?” The easiest response to this would be that, Grhya Sutra really stresses on the procedure of the different rites and goes really into details. On the other hand, Dharma Sutra accounts for the various customs and practices connected with these rites excluding the details of procedure. Although some of the topics covered in both the sutras are similar, they are both independent types of works apparently composed to serve different purposes.

Before going any further into the details of the Dharma Sutras, we should know the differences between Dharma Sutras and Dharma Sastras. Both of these texts are closely connected as both deals with the same or allied topics (Banerji 2). Even then there are differences to be noted between them. There are eight main points of differences; Form, Language, Divine Origin, Arrangement of topics, Historical priority, and Affiliation. Form: majority of the work of Dharma Sutras is composed in text intermixed with verse, however for the Dharma Sastras, it is entirely in verse. Language: Dharma Sutras contains many outdated forms than the Dharma Sastras. Affiliation to Vedic School: most of the Dharma Sutras betray some preference in the quotations for certain Vedas or Vedic Schools whereas the Dharma Sastras do not (Banerji 2). These are just some of the differences between Dharma Sutras and Dharma Sastras.

To this day, the only four remaining works which are related on the topic of Dharma are the Āpastamba, Baudhāyana, Gautama and Vasistha (Olivelle 3). Āpastamba and Baudhāyana are the only two Dharma Sutras that were brought down from Kalpa Sutras (Olivelle 3). Majority of the work which dealt with dharma appeared to have been composed during the Common Era.

The Āpastamba contains thirty praśnas (lit., “questions”) or books. Of these, the first 24 compromises of the Śrauta Sutra, 25-26 compromises of the collections of ritual formulas to be used in domestic rites, 27 compromises of the Grhya Sutra, 28-29 compromises of the Dharma Sutra and the final book on Śulva Sutra. The Āpastamba belongs to the Taittirīya branch of the Black Yajurveda. It has been conserved better than the rest of the Dharma Sutras. This could be proved by the only one surviving commentary of Haradatta (Olivelle 20). The laws of the Āpastamba are very straight forward and strict as it is the oldest Dharma Sutras. It deals with matters of civil law such as inheritance and brief sections on the orders of life. An example of a law of the Āpastamba underlying the caste system is that: “If someone kills a Ksatriya, he should give a thousand cows to erase the enmity, a hundred if he kills a Vaiśya, and ten if he kills a Sudra.” (Olivelle 61)

The Gautama Dharma Sutra did not have any connection with the Kalpa Sutras. It was composed as a separate thesis. Traditionally, the Gautama has been associated with the Sāmaveda (Olivelle 116). This is proved in the book, the twenty-sixth chapter, where the atonement is taken from the Sāmavidhāna Brāhmana which belongs to the Sāmaveda. Only one of the two commentaries could be said is a useful source. That was by Maskarin; however the other commentary by Haradatta is not really a useful source as he merely worked on what Maskarin had wrote before. This would be plagiarism in today’s world. An example of a law of the Gautama underlying the caste system is that: “If someone kills a Ksatriya, he should observe the standard vow of chastity for six years and give a thousand cows together with a bull; if he kills a Vaiśya, he should do so for three years and give a hundred cows together with a bull; and if he kills a Śūdra, he should do so for one year and give ten cows together with a bull.” (Olivelle 175)

The Baudhāyana Dharma Sutra is also part of the Kalpa Sutras just like the Āpastamba. Āpastamba was preserved really excellent compared to the rest of the Dharma Sutra; however Baudhāyana text was tampered around and inter-mixed a lot. Baudhāyana contains more detailed descriptions of rituals- sacrifices, twilight worship, bathing, quenching libations than any other Dharma Sutras (Olivelle 191). An example of a law of the Baudhāyana underlying the outcaste system is that: “When someone associates with an outcaste- not, however, by officiating at his sacrifices, by teaching him, or by contracting a marriage with him- but by traveling in the same vehicle or sitting on the same seat as he, or by eating together with him, he himself becomes an outcaste within a year.” (Olivelle 249)

The Vasistha Dharma Sutra, just like the Gautama Dharma Sutra, did not have any connection with the Kalpa Sutras. It also came down as a separate text. Traditionally, Vasistha has been associated with the Rgveda (Olivelle 346). It does not have a strong ancient commentary to prove its work; therefore, Vasistha Dharma Sutra might also have addition of works from different people over time. The Vasistha represents a trasitional phase from the prose Dharma Sutras to the verse Smrtis (Olivelle 346). An example of a law of the Vasistha is that: “If someone kills a Ksatriya, he should do the same for eight years; if he kills a Vaiśya, for six years; and if he kills a Sudra, for three years.” (Olivelle 435)

The Dharma Sutras were not really investigated well in Hindu studies in the past. It has limited sources and commentaries notes to prove its accurate date and existence. However, from the following books of sources, which guided me through this article, the related websites which gave me some knowledge on this topic, Dharma Sutras is indeed a wide text. From the four remaining Dharma Sutras, Āpastamba, Gautama, Vasistha and Baudhāyana we can see similar laws but phrased in different ways. The punishment for the same concept of sin done is different or phrased differently within the Dharma Sutras. Therefore one has to read and understand the different Dharma Sutras in general and also in detail.

BIBLIOGRAPHY

Olivelle, Patrick (2000) Dharma Sutras: The Law Codes of Apastamba, Gautama, Baudhayana, and Vasistha. Delhi: Motilal Banarsidass Publishers

Creel, B Austin (1977) Dharma in Hindu Ethics. Calcutta: South Asia Books

Singh, Balbir (1981) Dharma: Man, Religion and Society. Atlantic Highlands, New Jersey. Humanities Press Inc. Atlantic Highlands New Jersey.

S. J. Sekhar, Vincent (2003) Dharma: In early Brahmanic, Buddhist and Jain traditions. Delhi: Sri Satguru Publications.

Banerji, Sures Chandra (1962) Dharma Sutras: A Study in Their Origin and Development. Calcutta: Sankar Bhattacharya for Punthi Pustak.

Websites Related to the Topic

http://www.san.beck.org/EC10-Social.html

http://www.hinduwebsite.com/sacredscripts/dharma/apa00.htm

http://www.oldandsold.com/articles25/hindu-3.shtml

http://www.hindubooks.org/women_in_the_sacredlaws/the_dharma_sutras/page9.htm

http://www.sacred-texts.com/hin/sbe14/sbe1403.htm

http://www.allstarz.org/religioustext/hin/sla/

http://www.britannica.com/ebi/article-59826

Written by Shova Gurung (Spring 2006), who is solely responsible for its content.