Widow's right of retention for non-payment of her dower is her

A widow whose dower is unpaid and who has lawfully, without force or fraud, obtained possession of her deceased husband's property may retain it until the dower is paid. In Maina Bibi v. Chaudhri Vakil Ahmad (1924) the Privy Council held that this right of retention is a personal right and gives her no title to the property, so she cannot sell or gift it. It is not a creation of the Dissolution of Muslim Marriages Act, 1939, which deals with judicial divorce.