गोविन्द भाष्य (श्रील बलदेव विद्याभूषण - अचिन्त्यभेदाभेद वेदान्त ब्रह्मसूत्र भाष्य सटीक)

athaitayoḥ pathor na katareṇa ca tānīmāni kṣudrāṇy asakṛd avṛttīni bhūtāni jīvanti jāyasva mriyasvety etat tṛtīyaṁ sthānam. tenāsau loko na sampūryate. "There are these two paths and there is also another path, where many tiny creatures live, and where they are ordered: Now you must be born.' and Now you must die.' It is because of this third place that the world never becomes filled." Aside from the worlds of the devas and the worlds of the pitās, there is another, a third world, the home of tiny creatures like mosquitoes, insects, and worms, creatures who do not go to the higher worlds, but are simply again and again ordered: "Now you must be born." and "Now you must die." In this way they are born again and again and they die again and again. That is the meaning. Their abode is this third world. It is said that sinners take birth in the bodies of these insects and other lower creatures. Their place is the third world because it is different from the first and second worlds: Brahmaloka and Dyuloka. Because they have not attained true knowledge and thus become able to travel to the world of the devas, and because they have not performed pious deeds and thus become able to travel to the world of the pitās, they become tiny creatures like mosquitoes and insects and they stay in a third world. That is why the other worlds do not become filled to overflowing. These creatures neither rise to nor descend from the celestial worlds of Dyuloka, and for that reason Dyuloka does not become overfilled. They stay in a third world, where they do not offer the fifth oblation in order to attain a new body. Sūtra 20 smaryate 'pi ca loke smaryate—affirmed in the Śmṛti-śāstra; api—and; ca—also; loke—in the world. The Smṛti-śāstras affirm that it is also in this world. Purport by Śrīla Baladeva Vidyābhūṣaṇa In this world also some pious persons, Droṇa and Dhṛṣṭadyumna are two examples, also attain new bodies without offering a fifth oblation. This is described in the Smṛti-śāstras. The words "api ca" (and also) hint that there are other examples also.