Some or all works by this author are in the public domain in India because they originate from India and their terms of copyright have expired. According to The Indian Copyright Act, 1957, all documents enter the public domain after sixty years counted from the beginning of the following calendar year (ie. as of 2022, prior to 1 January 1962) after the death of the author.

Some or all works by this author are also in the public domain in the U.S.A. because it was in the public domain in India in 1996, and no copyright was registered in the U.S.A. (This is the combined effect of India's joining the Berne Convention in 1928, and of 17 USC 104A with its critical date of January 1, 1996.)

Some or all works by this author are in the public domain in the United States because they were published before January 1, 1927.

The author died in 1945, so works by this author are also in the public domain in countries and areas where the copyright term is the author's life plus 75 years or less. Works by this author may also be in the public domain in countries and areas with longer native copyright terms that apply the rule of the shorter term to foreign works.