"Judicial Exposition of the Expression "Acts done under official Capacity" and relevance of notice under section 80 of the Code of Civi
INTRODUCTION OF TOPIC
"Justice delayed is justice denied"
Justice is the foundation and object of any civilized society. The quest for justice has been an ideal which mankind has been aspiring for generations down the line[1]. Justice if not properly rendered in time is same as not having any redress at all.
India derives most of its judicial framework from the British legal system. A set of courts have been established at different levels i.e. the district courts at district level, High courts at state level and Supreme court at the national level. The aim for establishing the court at various levels is firstly to reduce the burden of judiciary and secondly to see to it that there is no miscarriage of justice.
In the 17th century various charters were introduced by the crown in the presidency towns of India. However certain changes were introduced in the 18th century and the presidency towns were brought under one uniform judicial system. At that time the personal laws were governed by the customs that were prevailing in India and the British introduced slight modifications in the personal laws of various religions in India.
There was no uniform code of civil procedure before 1859. Different codes were applicable in different parts of the country. The code that came into existence in 1859 had various defects in it like the said code was not at all applicable to the Supreme courts and the courts in the presidency town hence the code was amended time to time to remove the defects and finally in the year 1908 the code of civil procedure was enacted which was applicable to whole of India.
Thereafter various codified laws were introduced by the British and one such law is the Code Of Civil Procedure (1908). The Code of Civil Procedure, 1908 was first codified in 1859, after the revolution of 1857, which resulted in the dissolution of the East India Crown and the Government of India was taken over by the British sovereign and this led to a surge in legal and administrative reforms. Before this time, the law in this important branch was almost chaotic. Subsequently, the re-enacted code of 1908 was adopted and has again been amended in 1976[2].
Section 80 of the code of civil procedure states the suits by and against the government. The 27th law commission Report of India once again emphasized that section 80 needs to be deleted from the code of civil procedure. The recommendation for the deletion of section 80 was first made in the 14th Law Commission report of India. The report also clearly mentions the reason why there should be deletion of section 80 from the code of civil procedure.
"The evidences disclose in the large majority of cases of the government or the public officer made no use of the opportunity afforded by the section. In most cases the notice given under section 80 remained unanswered till the expiry of two months provided by the section. It was also clear that in a large number of cases, governments and public officers utilized the section merely to raised technical defenses contending either no notice was given or the notice given was did not comply with the requirements of the sections and this technical defence appears to have been succeeded in a number of cases defeating the just claims of the citizens[3]".
Thereafter the 54th law commission report gave its recommendation that were fully contrary to its earlier recommendations given by the commission in the report pertaining to section 80 was;
- In every suit where the party is the government or where the officer has acted in his official capacity it shall be the duty of the court to make all the efforts to assist the party in arriving a settlement.
- Also if in any suit it appears to the court that there is a chance of settlement between the parties then the court for the time being will adjourn the matter and make attempts to make such a settlement.
It was basically after the 54th law commission report of India the Code of civil procedure went through various changes to remove the defects from time to time. The amendment act of 1976 which came into effect from 1st February 1977 saw the change in the number of section and also sub section (2) and (3) have been inserted.
Then in the year 1984 the 100th law commission report again was of the view that section 80 of CPC which states that prior notice needs to be given to the government or the officers acting in its official capacity needs to be repealed.
Further the law commissions report no 221 gave few recommendations pertaining to section 80 which on can say was to an extent contrary to the earlier recommendations given by the law commission in its earlier reports.
This report emphasized on the point that there is as such no need to repeal section 80 of the code of civil procedure but what is required is to introduce parallel provision along section 80 of CPC so as to see to it that there is speedy disposal of case. Basically the object behind issuing of notice and the legislative intent behind the enactment of such a section is to give the other side (Government & public official who has acted in its official capacity) the opportunity to reconsider the claim for which the suit would be filed against him. Also to see to it that if it is possible then to solve the issue without any litigation because it would unnecessary waste the time and money of the parties. The object of the above section is to see to it that there is advancement of justice and also see to it that Public welfare is secured by avoiding unnecessary litigations.
The following recommendations were given by the above report:
- That as such notice of two months needs to be given but if the matter is urgent then with the prior permission of court one can institute the suit. The commission was of the view that a similar provision need to be introduced were it will be mandatory to give notice to the other party before institution of suit i.e. he must give a copy of plaint through registered post and thereafter he must file an affidavit along with his plaint stating the fact of service of notice along with a copy of plain[4].
- Amendment of Section 80 and order 5 of the Code of Civil procedure, 1908 and also the concerned court rules – In order to shorten delays, it is necessary that provisions parallel to section 80 of Code of Civil Procedure 1908 be introduced to all kinds of civil suits and cases proposed to be filed by a litigant[5] .
Nature and Scope of the Study
The nature of the study is doctrinal i.e. along with referring the case laws the researcher has referred different sources such as books, journals, reports, articles and net. The scope of my study is confined to implications and interpretations of section 80 of Code of Civil procedure, 1908.
Objectives of the study
- To know the judicial view of the expression "Acts purporting to be done under official capacity" under section 80 of the code of civil procedure, 1908.
- To know the judicial view on the importance of notice under section 80 of the code of civil procedure,1908.
Hypothesis
- That if notice is not given to the opposite party who has acted in his official capacity then the suit is itself defective.
- That the expression "acts purporting to be done under official capacity" includes all the acts that the person has done during the course of his regular routine.
- That a suit in no case can be instituted against the person who has acted in his official capacity' without prior notice.
Research Methodology
The work undertaken by this researcher is mainly doctrinal and analytical. The researcher has utilized the conventional method of using libraries and sourced information from various Law Journals which have published the Judgments passed by the Supreme Court and High courts.
The study being doctrinal in nature historical methods is adopted because it is not possible to rely on purely experimental methods.
The relevant material has been collected from legal sources like books on Code of Civil Procedure by eminent authors like Avtar Singh, Basu, Mulla, and Justice C.K.Takwani. Material was also researched from print and electronic media
The information thus collected has helped the researcher to critically analyze the topic and reach the core aspects of the study.
CHAPTER -2
- Legal Provisions
Legal Provisions
80. Notice[6].
1[(1)] 2[Save as otherwise provided in sub-section (2), no suits 3[shall be instituted] against the Government (including the Government of the State of Jammu & Kashmir)] or against a public officer in respect of any act purporting to be done by such officer in his official capacity, until the expiration of two months next after notice in writing has been 4[delivered to, or left at the office of]-
(a) in the case of a suit against the Central Government, 5[except where it relates to a railway], a Secretary to that Government;
6[7[(b)] in the case of a suit against the Central Government where it relates to railway, the General Manager of that railway];
8[(bb) in the case of a suit against the Government of the State of Jammu and Kashmir the Chief Secretary to that Government or any other officer authorised by that Government in this behalf;]
(c) in the case of a suit against 9[any other State Government], a Secretary to that Government or the Collector of the district; 10[***]
11[***]
and, in the case of a public officer, delivered to him or left at this office, stating the cause of action, the name, description and place of residence of the plaintiff and the relief which he claims; and the plaint shall contain a statement that such notice has been so delivered or left.
12[(2) A suit to obtain an urgent or immediate relief against the Government (including the Government of the State of Jammu & Kashmir) or any public officer in respect of any act purporting to be done by such public officer in his official capacity, may be instituted, with the leave of the Court, without serving any notice as required by sub-section (1); but the Court shall not grant relief in the suit, whether interim or otherwise, except after giving to the Government or public officer, as the case may be, a reasonable opportunity of showing cause in respect of the relief prayed for in the suit:
Provided that the Court shall, if it is satisfied, after hearing the parties, that no urgent or immediate relief need be granted in the suit, return the plaint for presentation to it after complying with the requirements of sub-section (1).
(3) No suit instituted against the Government or against a public officer in respect of any act purporting to be done by such public officer in his official capacity shall be dismissed merely by reason of any error or defect in the notice referred to in sub-section (1), if in such notice-
(a) the name, description and the residence of the plaintiff had been so given as to enable the appropriate authority or the public officer to identify the person serving the notice and such notice had been delivered or left at the office of the appropriate authority specified in sub-section (1), and
(b) the cause of action and the relief claimed by the plaintiff had been substantially indicated[7].]
The above section delineates the procedure to be followed while bringing the suit against the government. Before filing a suit the plaintiff has to give a two-month notice to the government or the public official against whom the suit would be instituted. The suit cannot be instituted once the time period of two month has passed. The reason being the government or the public official must be given an opportunity to reconsider his decision and if possible to settle the claim without institution of suit. The procedure eliminates wastage of time and money in unnecessary suits which can be settled without litigation.
A notice served under section 80 of the code of civil procedure gives the Government sufficient warning of the case which is going to be instituted against it so the government may settle the claim without litigation[8].
Thus, section 80 of the Code of Civil Procedure is a procedural law through which the court will dispense justice between the parties.
The notice will be held valid only if it fulfills the conditions like including the name, description and residence of the plaintiff, the cause of action and the relief which the plaintiff claims; also, it must convey to its recipient the information through which the other person may consider his claim.
CHAPTER – 3
- Judicial Trend
Judicial Trend
In U.R.Agarwal v Bharm Singh And others[9] The question before the honorable Allahabad High Court was whether a suit can be instituted under Section 80 of the code of civil procedure if notice is not given to the public official who has acted in his official capacity.
Here the court was of the view that if no notice under Section 80, Civil Procedure Code was given, the suit itself would be defective. Hence the honorable court rejected the plaint on the above stated ground.
A similar view was taken by the honorable High court of Andhra Pradesh in Paleti Sivaramakrishnaiah Vs Executive Engineer, N.C. Canals Sathenapalli and Anr[10].
In Taru Rani Choudhary Vs. Cantonment Board, Dinapore and Ors.[11] The plaintiff instituted a suit against the defendants alleging that she is the absolute owner of the suit house through purchase and as some of the portions of the said house were in a dilapidated condition she had got the repairs done. The Dinapore Municipal Board had served notice on the plaintiff for demolition. At the instance of the plaintiff the Cantonment Board recommended for rectification of the alleged offence on payment of Rs. 50/- as compensation fee. The said resolution of defendant 1 was forwarded to defendant No. 3, the Military Estate Officer for onward transmission; however, defendant No. 5 asked the plaintiff under instruction to submit a registered acknowledgment deed admitting Government's title over the land comprising the suit house. On being refused by the plaintiff the above recommendation of the Board was turned down and another notice for demolition was issued which was challenged as illegal by the plaintiff through the present suit. The petition was refused by the lower appellate court on the ground that it did not fulfill certain conditions of section 80 of the Code Of Civil Procedure.
On appeal the court was of the view that in a suit filed against a public officer, notice is mandatory only if the offence was the act of a public officer in his official capacity. Otherwise no such notice is necessary.
Section 273 of the Cantonments Act provides for a notice before instituting such a suit against the Cantonment Board or its officers; also, the language of the above section is similar to section 80 of CPC. In the present appeals no doubt the plaintiff has alleged illegal threats against her by the officers of the Board in taking steps for demolition of the construction raised by her. The court is of the view that the two sections do not constitute absolute bar and hence, the court cannot reject the whole plaint on the hypothesis that the provisions of Section 80 (2nd part) of the Code and those of Section 273 of the Cantonment Act has constituted absolute bar. The court held that the findings of the lower appellate Court rejecting the whole plaint, as aforesaid are set aside, the appeal is allowed in part and the same is remanded for fresh disposal
In Sivananda Roy vs Janaki Ballav Pathanaik and ors[12] Here the the plaintiff an advocate by profession at Bhuvneshwar booked a suit for his friend at the Guest House of the Orissa State Electricity Board for 28/10/1980.On the said date the plaintiff, his friend and family reached the hotel only to discover that the room had already been allotted to a lady, a friend of the then chief Minister of Orissa. The Plaintiff alleged that he suffered humiliation due to the breach of the contract hence he filed a plaint in the court .One of the contentions of the plaintiff is that J.B.Patnaik who happened to be the chief minister of the state as well as one of the defendants(Defendant no.4) in this case was impleaded in the suit in his individual capacity for which notice under Section 80, C.P.C. is not necessary. "The learned Munsif found that notice under Section 80, C.P.C. should have been sent prior to the institution of the suit or at least the leave of the Court should have been taken as per the provision of Section 80, C.P.C. in absence of which the suit was incompetent as against defendant No. 4. The learned Munsif also found that no cause of action had been disclosed in the plaint against defendant No. 4. The learned Munsif rejected the plaint so far as defendant No. 4 is concerned and directed that the name of defendant No. 4 should be struck off the cause title of the plaint[13]".
The plaint was also rejected for want of notice under Section 80, C.P.C. A notice under Section 80, C.P.C. is a prerequisite for a suit against the Government or against a public officer in respect of any act done or purporting to be done by such public officer in his official capacity. Non-compliance of the requirement of Section 80, C.P.C., where it is necessary, may be a ground for rejection of a plaint under Order 7, Rule 1 (d) C.P.C. However, as this is not a case where the plaintiff can be found fault with the rejection of the plaint for non-compliance of the mandatory provision of Section 80, C.P.C. is not supportable.
Thus this revision stands dismissed on merits as one of the grounds for rejection by the learned Munsif as against defendant No. 4 is sound in law.
In: Vishnu Wasudeo Joshi Vs. T.L.H. Smith Pearse[14] The appellant was an Electrician in the employment of the Rajkumar College, Raipur, where the respondent was the Principal of this College at the material time. The allegation was that the respondent suspended him on one occasion and while taking charge of the College property, the respondent kicked him once or twice in the ribs. This act not only caused mental and physical anguish to him but even lowered him in the estimation of others. He, therefore, claimed Rs. 100 as damages.
The question arose whether the respondent is a public officer under the ambit of section 2(17)of the Code of Civil Procedure Code. The plaintiff had given the notice to the respondent but as per section 80 a plaint can only be filed after completion of the 2 months from the date of notice which was not followed here.
Section 2(17) states that
Public officer' means a person falling under any of the following descriptions, namely
(a) every Judge;
(b) every member of the Indian Civil Service;
(c) every commissioned or gazetted officer in the military or naval forces of His Majesty, including His Majesty's Indian Marine Service, while serving under the Government,
(e) every person who holds any office by virtue of which he is empowered to place or keep any person in confinement;
(g) every officer whose duty it is, as such officer, to take, receive, keep or expend any property on behalf of the Government or to make any survey, assessment or contract on behalf or the Government, or to execute any revenue-process, or to investigate or to report on any matter affecting the pecuniary interests of the Government, or to make, authenticate or keep any document relating to the pecuniary interests of the Government, or to prevent the infraction of any law for the protection of the pecuniary interests of the Government; and
(h) every officer in the service or pay of the Government, or remunerated by fees or commission for the performance of any publics duty.
The court held that the respondent here could be termed as public officer as per section 2(h) because he was on deputation to the Rajkumar College and received his pay from that institution; he did not cease to be in the service of the Crown by reason of his deputation.
The second important question was whether his act was done in his capacity as public officer. Here the court held that an act done by the person within the scope of his official duty for instance kicking the person or a mere gentle touch had nothing to do with his official duty. In the circumstances there was no need for a notice under Section 80, Civil Procedure code. Hence the court passed the decree in favor of the appellant.
In State of Bihar v. Raghunandan Singh[15],. The Patna High court held notice under Sec. 80 is not necessary for a suit for permanent injunction restraining the Government from settling the ghat in suit in near future. Raj Kishore Prosad, J., observed that the meaning and the correct interpretation of the words, "in respect of any act purporting to be done", occurring in Section 80 of the Code, is that they cover only a past act and do not include a future act. Section 80, as such comes into play only when the suit begun is in respect of past acts, completed, or begun, but incomplete, but it does not apply to future or threatened acts[16]."
In Trustees Bombay Port's case[17]In this case the question that came before the court was that whether short delivery by a statutory bailee was something done or purporting to have been done under the provisions of that Act The court in did not agree with the contention as the necessary notice required as per the sections 87 of Bombay Port Trust Act was not given before filing of suit. Further the court also explained the expression "Acts purporting to be done under official capacity" and was of the view that that " What is done under purported exercise of statutory functions, even if in excess of or contrary to its provisions, is done pursuant to or under the Act so long as there is a legitimate link between the offending act and the official role"[18]. The above decision was also affirmed in BombayHousing Board's case[19].
Also the full bench of the Allahabad High Court in the case of Antarim Zila Parishad v. Shanti Devi[20] elaborated the'an act done or purporting to have been done in its or his official capacity" as follows
"If an act comes within the scope of the duties, powers or functions of the authority created by the statute. It may also be an act done under the Act or statute. The words "done under an Act" require more direct connection between the act and the statute than 'done under the official capacity of authority', it must be an act directly required or permitted, expressly or by necessary implication, to be done by the statute. If a statute authorizes the doing of an act it is an act done under the statute, it is also done under the authority of the statute; or in the official capacity of the doer. An act done, though not under an express or implied provision of a statute but in performance of a statutory duty or in exercise of a statutory power or function is done under the authority of the statute. If the statute confers an official status or capacity upon the doer it is done under the official authority or in the official capacity[21]."
Similarly the court in Jalgaon Borough Municipality v. Khandesh Spinning and Weaving Mills Co, Ltd[22]The court in this case gave a distinct difference between the acts done with semblance of authority and a prima facie illegal act held that an act which is prima facie illegal is not within the category of acts done or purported to have been done in pursuance of that Act, and that it is only an act done under a vestige or semblance of authority or with some show of a right that would fall within the category. And that the distinction between ultra vires and illegal acts on the one hand and wrongful acts on the other -- wrongful in the sense that they purport to have been done in pursuance of the Act -- is that they are intended to have been done in pursuance of the Act and are done with a vestige or semblance of authority or sort of a right invested in the party doing those acts[23].
In State of Maharashtra and Anr. Vs. Shri Chander Kant[24] In this case the respondent filed the suit against the state claiming that the order in 1955 in Revenue case declaring Gajanan Maharaj Sansthan of Mangrul-Dastagir to be a public trust be set aside. The plaint was filed under Section 8(1) of the Public Trust Act (M.P. Public Trusts Act 1951) against the State of Madhya Pradesh and the Registrar of Public Trust, Amraoti. It is admitted by the parties that no notice under Section 80 of the CPC was given.
The defendents held that no notice as per section 80 of the CPC. The Additional District Judge held a notice under Section 80 of the CPC was necessary and the suit was not maintainable and ordered the dismissal of the suit.
The Supreme court was of the view that these provisions indicate that the Registrar is a Public Officer. The words "act purporting to be done in official capacity" have been construed to apply to non-feasance as well as to misfeasance. The word "act" extends to illegal omissions. Section 80 of the CPC therefore is attracted when any suit is filed against a Public Officer in respect of any act purporting to be done by such Public Officer in his official capacity. Hence in the present case the court was of the view that a public officer comes under section 80 of the Code of civil Procedure and hence notice is mandatory.
In Koti Reddy v Subbiah [25]. The court elaborated the expression "Act purporting to be done under official capacity" under section 80 of the Code of Civil Procedure 1908,The court opined that all acts done under the guise by an officer under the ordinary course of its official duty would be very much included in the above expression.
In State of Madras v Venkata Durga State of Madras v Venkata Durga [26]. The court held that if there are any allegations from the plaintiff pertaining to the "act purporting to be done under official capacity" then notice becomes mandatory as per section 80 of the code of civil procedure1908. Also in one of the cases the honorable J&K High court [27]held that if official act is done even with mala fide intention in the course of his official duty then also it will be termed as official act and section 80 would be very much applicable.
In Chhaganlal v Collector of Kaira[28] The honorable Bombay high court was of the view that the expression "Act purporting to be done under official capacity" under section 80 of the Code of Civil Procedure 1908,act which is ordinarly done by a person in the normal course of his duty and does not include any act which is outside the ambit of his duty.
In Ram Kumar and Anr. Vs. State of Rajasthan and Ors. (Decided on 29.09.2008)[29].
Trial court decided the issue, on the ground that the respondent had not acted in his official capacity in the present case and, therefore, service of notice under Section 80 of the CPC on respondent was not necessary, whereas the High Court reversed the order of the trial Court and held that the respondent had acted in his official capacity and, therefore, non service of the notice on Respondent would invite the court to dismiss the suit in its entirety. The suit which is not in respect of any act done by the respondent , as a public officer, and in which no act of respondent is either challenged or sought to be set aside is not a suit to which Section 80 of the CPC can very well apply. Therefore, respondent had not acted in his official capacity for which service of notice under Section 80 of the CPC was necessary. High Court had fallen in error in reversing the order of the trial Court holding that service of notice on respondent under Section 80 of the CPC was not necessary to be served to maintain the suit A look at the relief's claimed in the plaint would clearly show that only a consequential relief was claimed in the suit to the extent that possession of the suit land should be restored in favor of the appellants by the respondent. Therefore, even in the absence of service of notice on the respondent under Section 80 of the CPC, the suit was maintainable in law[30].
The Honorable supreme court in Bihari Chowdary v State of Bihar [31] was of the view that the intent of the legislature for the enactment of section 80 is to see to it that before institution of suit notice must be instituted so as to make the other party scrutinize his act and if possible to settle the claims outside the court i.e. one should try to avoid unnecessary litigations.
Chapter-4
- Conclusion
- Suggestion
CONCLUSION
The researcher after completing his project has come to certain conclusions which would indirectly prove the hypothesis presumed by the researcher.
The concept of notice under sec.80 of CPC is to prevent litigation and wastage of money and time of the parties. It was inserted under sec 80 with the object of reducing the burden on the judiciary and if possible solve the matter without drawing each other in litigation.
The first hypothesis presumed by the researcher "that if notice is not given to the opposite party who has acted in his official capacity then the suit is itself defective" is clearly proved. The judiciary in various cases is of the view that there are certain pre-requisites of section 80 which need to be followed and if not followed then the suit cannot be entertained by the court. One such important pre-requisite is notice under sec 80 which if not given within two months from the date of institution of suit to the opposite party then the suit would be dismissed.
The second hypothesis presumed by the researcher "that the expression "acts purporting to be done under official capacity" includes all the acts executed by the person during work. To this the judiciary is of the view that act done under official capacity excludes illegal acts for which he has no authority; also, it includes only past acts and not future acts;
"The court opined that all acts done under the guise by an officer under the ordinary course of its official duty would be very much included in the above expression"[32].Hence the second hypothesis presumed by the researcher to an extent is true..
Finally, the last hypothesis presumed by the researcher "That a suit in no case can be instituted against the person who has acted in his official capacity' without prior notice" is proved as even the judiciary is of the view that notice is a must under sec.80 to prosecute any public official for his act.
CHAPTER -5
1.Bibliography
- Books
- Journals
- Reports
- Web References
- Case laws
BOOKS
- Basu's. Code of Civil Procedure, New Delhi: Ashoka Law house
REPORTS
- 14th law commission report
- 27th law commission report
- 54th law commission report
- 100th law commission report
- 221st law commission report
JOURNALS
- All India Reporter
WEB REFERENCES
- www.manupatra.com
- www.commonlii.org
ARTICLES
- Sinha S.B. ‘ADR and access to Justice: Issues and Perspectives'
- Balakrishna K.G. ‘An overview of Indian Justice Delivery Mechanism'.
CASE LAWS
- U.R.Agarwal v Bharm Singh And others (AIR1976All243)
- Paleti Sivaramakrishnaiah Vs Executive Engineer, N.C. Canals Sathenapalli and Anr (AIR1978AP389)
- Taru Rani Choudhary Vs. Cantonment Board, Dinapore and Ors (AIR1982Pat204)
- Sivananda Roy vs Janaki Ballav Pathanaik and ors (AIR1985Ori197)
- Vishnu Wasudeo Joshi Vs. T.L.H. Smith Pearse(AIR1949Nag362)
- State of Maharashtra and Anr. Vs. Shri Chander Kant(AIR1977SC148)
- Koti Reddy v Subbiah(AIR 1918 Mad 62)
- State of Madras v Venkata Durga State of Madras v Venkata Durga(AIR 1957 AP 675)
- AIR 1968 J&K 98
- Chhaganlal v Collector of Kaira((1910) 35 Bom 42)
- Ram Kumar and Anr. Vs. State of Rajasthan and Ors. (Decided on 29.09.2008)
- Bihari Chowdary v State of Bihar((1984) 2 SCC 927)
[1] Sinha S.B. ‘ADR and access to Justice: Issues and Perspectives'
[2] Balakrishna K.G. ‘An overview of Indian Justice Delivery Mechanism'.
[3] 27th law commission report
[4] Government of India, Law commission of India , Report number 221
[5] Government of India, Law commission of India , Report number 221
[6] www.commonlii.org
[7]
[8] Basu's. Code of Civil Procedure, New Delhi: Ashoka Law house
[9] :AIR1976All243
[10] AIR1978AP389
[11] AIR1982Pat204
[12] : AIR1985Ori197
[13] AIR1985Ori197
[14] AIR1949Nag362
[15] AIR 1960 Pat 530
[16] Ibid
[17] [1974]3SCR397
[18] Ibid
[19] [1975]3SCR407
[20] AIR1965All590
[21] AIR1965All590
[22] AIR1953Bom204
[23] Ibid
[24] AIR1977SC148
[25] AIR 1918 Mad 62
[26] AIR 1957 AP 675
[27] AIR 1968 J&K 98
[28] (1910) 35 Bom 42
[29] www.manupatra.com
[30] Ibid
[31] (1984) 2 SCC 927
[32] AIR 1918 Mad 62
About the Author
Varun Rajesh Israni
3rd year student
Institute of Law, Nirma University
Leading@Google: Mike Useem
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