According to the Mitakshara, property acquired by means of learning would be self-acquired provided that learning was obtained without detriment to the ancestral property.
The Privy Council drew a distinction between ordinary education and specialised training. When a person receives ordinary education though this was done at the expense of the ancestral property, subsequent acquisitions by him, through based upon such ordinary education received by him are his self-acquired property, Mehta Ram v. Rezva Chand, 45 Cal. 666 (PC) (Acquisition made by a stock broker).
When, however, the education is of a specialised kind, the use of ancestral property for having such education makes the subsequent acquisitions attributable to such specialised training coparcenary property.
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Thus in Gokul Chand v. Hukam Chand, 2 Lah. 40 (PC) joint family properties were utilized to send a coparcener to England and educate him there so that he became a member of the Indian Civil Service (I.C.S.). It was held that the salary of the officer becomes a joint family asset in such a case. Accordingly it was held to be attachable in execution of decree debt binding upon the family.
The decision in Gokul Chand’s case led to the passing of the Hindu Gains of Learning Act of 1930. By this Act (known as the Jayakar Act) this decision was statutorily superseded. Under this Act gains of learning are only self-acquired property, whether the education imparted happens to be ordinary education or specialised education. Gains of learning are thus always self-acquired property as a result of this Act.