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37. Smriti also states this.

Smriti also declares that men not belonging to an âsrama grow in knowledge through prayer and the like. 'Through prayer also a Brâhmana may become perfect. May he perform other works or not, one who befriends all creatures is called a Brâhmana' (Manu Smri. II, 17).

Next: 38. And there is the promotion of knowledge through special acts of duty