"The belief in the authenticity of Kulluka's text was openly articulated by Burnell (1884, xxix): "There is then no doubt that the textus receptus, viz., that of Kulluka Bhatta, as adopted in India and by European scholars, is very near on the whole to the original text." This is far from the truth. Indeed, one of the great surprises of my editorial work has been to discover how few of the over fifty manuscripts that I collated actually follow the vulgate in key readings."
Manusmriti

January 1, 1970