四分律行事鈔資持記 2.355

2.355

法中。亦約施者之意。初言通故，人法兩用；下云寶者，以別指故。準知西竺三寶，皆置理塔。

Regarding the Dharma: it is also based on the donor's intention. Because the beginning states that it is general, it serves both person and Dharma; below it says "Jewel," because it designates specifically. From this one can know that in India, all the Three Jewels had principle-stupas established.