SECTION 53: FRADULENT TRANSFERS

TRANSFER OF PROPETY ACT,1882

Submitted by:

Suyogaya Awasthy

2014127

SEMESTER V

DAMODARAM SANJIVAYYA NATIONAL LAW UNIVERSITY

Visakhapatnam

OCTOBER 2016

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 CERTIFICATE

Title of the subject: TRANSFER OF PROPERTY ACT,1882

Name of the faculty: Mr. P.JOGI NAIDU SIR

I, Suyogya awasthy, hereby declare that this Project titled submitted by me is an original
work undertaken by me. I have duly acknowledged all the sources from which the ideas and
extracts have been taken. The projects free from any plagiarism issue.

(Signature of the candidate)

Place: Visakhapatnam Name: Suyogya Awasthy
Date: 21/10/16 Roll No. 2014127
Semester V

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Table of Contents

Table of Cases 04

Introduction 05

Section 53 & Its Essentials 05

English Law on Fraudulent Transfers 06

Indian Law on Fraudulent Transfers 07

Sham Transfers 08

How Fraudulent Intention in the Transfer Can Be Proved 09

If there are Several Creditors 10

Exceptions to Section 53 (1) 12

Section 53 (2): Gratuitous transfer to defraud subsequent transferee 13

Burden of Proof 13

Conclusion 14

Bibliography 15

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Table of Authorities
Table of Cases:
Twynes case. 05

Edwards v. Harben 05

Sunder Lal v. Gurusaran Lal 06

Nath v. Dhunbaiji 06

Joshua v. Alliance Bank 06

Jangali Tewari v. Babban Tewari 07

Petherpermal Chetty v. Muniandi Servai 07

Immani Appa Rao v. Gollapalhili Rama Lingamurthi 07

Mina Kumari v. Bijoy Singh 10

Chogmal Bhandari v. Deputy Commercial Tax Officer, Kurnool 10

Musahur Sahu v. Hakim Lal 11

Middleton v. Collak 11

Vinayak v. Kaniram 12

Kapini Goundan v. Sarangapani 12

Chandradip v. Board of Revenue 13

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 CHAPTER 1
INTRODUCTION
Every owner of a property has right to transfer his property as he likes. There
must be a bonafide intention to transfer. If there is a Fraudulent Intention, the
intention of defeating the interest of creditor or interest of any subsequent
transferee, the transfer is not valid in the eyes of law. These transfers arise in
debtor and creditor relations, particularly with insolvent debtors. The action
against such debtors is typically brought by creditors or by bankruptcy trustees.
Here in fraudulent transfer, the object of transfer would be bad in eyes of equity
and justice though it is valid in law. In some cases fraudulent transfers are valid
in law but not void, but because they are made with malafide intention, equity
would render it voidable by the person who was so defrauded. This principle of
equity has been incorporated in Section 53 of Transfer of Property Act, 1882.
This section disallows a person to convey or alienate his property when such
conveyance defeats or delays the interest of his creditor or any subsequent
transferee.

TRANSFER

The transfers referred to in this section are transfers binding between the
parties, but voidable in the circumstances stated in the section. A document
made to defeat or to delay his creditors is binding on the executant, and those
claiming under him. The transfer is valid until it is set aside, and must not be
confused with benami or colourable transfers which are merely sham transfers,
and not meant to operate between the parties. In the collusive or benami
transactions there is no transfer, but the property is merely put in a false name,
and generally for the purpose of defrauding creditors. As observed by Sir
Lawrence Jenkins in Mina Kumari v Bijoy Singh,1 the difference is distinct
though it is often flurred. Such colourable or sham deeds do not require to be set
aside, for the real title is all along with the transferor. They are outside the scope
of the section.2 It is relevant to note that a contention that the transaction is a
sham and nominal transaction, and that the property was never conveyed at all,
and remained the property of the original owner, may go even contrary to the
contentions raised that are based upon S 53 of the TP Act. If the contention that
it is a sham and nominal transaction is accepted, S 53 may not have any

1(1916) ILR 44 Cal 662, 44 IA 72, 40 IC 242, AIR 1916 PC 232.

2 Prabhu nath v. sarju Prasad AIR 1940 All 407.

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application. Infact, the challenge based on S 53 involves the admission that the
transfer is a real one.3
Transfer includes a sale4; a grant under a 1ease5 including a lease created
by a mortgagor6 transfer by way of a Mortgage or one by exchange or an oral
gift under Muslim law. Any transfer made with the permission of the court and
in accordance with the terms imposed by it will not be subject to the rule of lis
pendens7.

CHAPTER 2
Section 53 & Its Essentials

Section 53 deals with the Doctrine of Fraudulent transfers. It provides that:-

Section 53(1) explains about
1. Transfers of an immovable property,
2. Made with intent to defeat or delay the creditors of the transferors,
3. Shall be voidable at the option of creditor so defeated or delayed.
But the exceptions to the provisions of this sub section are-
a) The rights of a subsequent transferee in good faith for consideration,
b) Any law for the time being in force relating to insolvency.
Section 53(2) explains about-
1. Transfer of an immovable property,

3 Chumar v. Alima AIR 1998 Ker. 139.

4 Gurmail Singh v. Udham kaur(deed) by Irs AIR 1999 P&H 300. See
generally [65] Civil Procedure.

5 Madan Mohun Singh v. Raja Kishori Kumari AIR 1917 Cal 222, (1917)
21 Cal WN 88.

6 Magan Lal jagjiwandas v. Lakhiram Haridasmal AIR 1968 Guj 193,

(1968) 9 Guj LR 161.

7 Sripat Singh v. Naresh Chandra Bose AIR 1926 Pat. 94.

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 2. Transfer without consideration and again transferred to another person,
3. The subsequent transferee may avoid the first transfer.
For the purpose of Section 53(2), if a transfer is made without
consideration, it is deemed to be made with intent to defraud.

CHAPTER 3
ENGLISH LAW ON FRAUDULENT
TRANSFERS

The English law regarding the fraudulent transfer is depended upon the
Twynes8 case. In this case Pierce was indebted to Twyne and also to C. C filed
a suit against Pierce for satisfaction of his debt, but when the suit was pending
in the court, Pierce who was in the possession of goods and chattels, in secret
made a general deed of gift of all his goods and chattels to Twyne, in
satisfaction of his debt, without any obstruction that Pierce continued in
possession of the goods, and marked them with his own mark. Afterwards C had
judgment against Pierce and when his goods were sought to be seized in
execution of the judgment, Twyne and others resisted. Here the question arises
whether the gift in favor of Twyne was fraudulent, the court held that:
1. The gift had the signs and marks of fraud, because the gift is general,
there is no necessity for the donor to do this. For it is commonly said,
quod dolosus vesatur in generalibus.( That this gift had the signs and
marks of fraud, because the gift is general, without exception of his
apparel, or any thing of necessity)
2. The donor continued in possession and used them as his own, so it clearly
shows that he had defrauded and deceived the creditor.
3. The gift was made in secret, et done clandestine sunt simper suspiciosa.
4. The gift was made during the pendency of suit.
5. Even after the gift was made, the donor was still in possession and
therefore here there was a trust between the parties and the fraud is
covered by the trust.
6. The gift deed contains that it was made truly, honestly and bonafide.
8 Reported in 3, coke, 80.

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So in this case we should observe that, even if there was a true debt due to
Twyne, but the gift which was made with no consideration and bonafide, and it
shall be deemed that a gift made with any trust in favor of donor is considered
to be done with fraud.
In another case regarding the same issue, Edwards v. Harben9, the judgment was
given by Buller,. J. he said if the possession is not followed by deed, it is
deemed to be done with fraudulent intent and it is void.

INDIAN LAW ON FRAUDULENT

TRANSFERS

Section 53 of TPA as it is originally stood was based on the statutes of

Elizabeth. Now, this section is in consonance with that of the English statute.
The first part of the section deals with the transfers in fraud of creditors, and the
second deals with the fraud of subsequent purchaser. A transfer though it may
not offend this section could be still be avoided either under Section 55 of the
Presidency Towns Insolvency Act, 1909, or Section 53 of the Provincial
Insolvency Act, 1920, and a provision saving insolvency law is introduced in
the section.
This section is applicable only where the transaction is transfer of property
within the meaning of Section 5 of the Act. In the case of Sunder Lal v.
Gurusaran Lal10, it was held that relinquishment of share by one co-parcener in
favor of other is not a transfer of property within meaning of this section and
Section 53 does not apply. Surrender is not a transfer of property, but in the case
of Nath v. Dhunbaiji11, the court held that surrender by a life-estate holder is a
transfer and it is covered by this section. In the case of Joshua v. Alliance
Bank12, a settlement was provided for the appointment and it was found that the
appointment was done to defeat or delay the creditors. Therefore observing the
facts, the court held that appointment made with reference to the settlement was
fraudulent transfer. Naturally a question arises regarding the Section 53 of TPA,

9 2 Term Rep. 587

10 A.I.R 1938 Oudh 65.

11 (1899) 23 Bom. 1.

12 (1895) 22 Cal. 185.

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that when the consideration is good in part. If the transfer was for the purpose of
delaying or defeating creditors, the transaction will be set aside as there was
fraud in it. But if a part of the consideration is utilized for paying off a mortgage
debt of the transferor, then either the transfer would be treated as valid to that
extent or if the transfer is set aside the vendee is given charge on the property.

CHAPTER 4
SHAM TRANSFERS
Sham transfer means fictitious transfer. When the transferor does not intend that
the property should be really vested in the transferee, such transfers are
therefore unreal or colourable and never meant to operate between the parties.
Such transfers are fictitious transfers. Benami transaction is also a sham transfer
because the real owner has no intention that property should belong to
ostensible owner. It can be clearly explained by the following cases.
In the case of Jangali Tewari v. Babban Tewari 13, a sham transfer is not a real
transfer at all. The intention of the real owner is not necessarily fraudulent. So,
such transfers do not require to be avoided because the real title already vests in
the transferor.
In the case of Petherpermal Chetty v. Muniandi Servai 14, a sale deed of land was
executed in June 1895 in favor of the predecessor of the appellant. The
transaction was a benami transaction, it was not real. An equitable mortgagee of
the land sued in September 1895, to establish his lien on the ground that the sale
was intended to defraud creditors and obtained a decree by which the equitable
mortgagee was paid off and the mortgage was discharged. On the death of the
vendor of the land, the appellant, legal representative of the purchaser was sued
by the heir of the vendor (respondent in the case) for the recovery of the land.
The defence argument was that the plaintiff, on account of his participation in
the fraudulent attempt to defeat his creditor, was not entitled to recover
possession of the land.
The court held that:-
Persons have been allowed to recover property which they had assigned away,
where they had the intention to defraud or delay creditors, who, in fact, were
never injured. But when fraudulent or illegal purpose has actually been effected

13 A.I.R 1982 All. 316..

14 (1907-08) LR 35 IA 98.

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by mean of the colourable grant, the legal maxim in pari delicto potior est
condition possidentis applies. The court will help neither party. It says let the
estate lie where it falls. To enable a fraudulent party to retain property
transferred to him in order to effect a fraud must, according to the authorities, be
effected. Then alone, does the fraudulent grantor or transferor, lose the right to
claim the aid or support of the law to recover the property he has parted with.
The principle however will not apply in the case if the transferor seeks for
possession from the transferee before the fraud is effectuated.
In the case of Immani Appa Rao v. Gollapalhili Rama Lingamurthi 15, a sale of
property was made with the mutual consent of the vendor and the vendee to
defraud the creditors of the vendor. There was no consideration and the
transferee also agreed to act as a benamidar until the transferor required him to
reconvey the property to his sons. The transferor and his sons trespassed and
occupied the property, as the creditors were defrauded. The transferor, in
defence, urged that the transferee has no rights in the property as the transfer
was a fraudulent transfer. So in this case the court observed that:-
The transferors emphasized that the doctrine which is pre-eminently applicable
to the present case is ex dolo malo non oritur action or ex turpi causa non oritur
actio. It means they contended that the right of action cannot arise out of fraud
or out of transgression of law. According to them it is necessary that the
possession should lie where it lies, in pari delicto potior est condition
possidentis. The law favors him who is actually in possession in case where
there is guilty of fraud on both the parties. The principle of public policy is that
no court will lend its aid to a man who founds his cause of action upon an
immoral or illegal act. If the cause of action arises from the plaintiffs side, the
court says that he has no right to be assisted; it is same in the case of defendants.
The Court also said that there is no question of estoppels in such a case because
the fraud in question was agreed by both the parties and both the parties have
assisted each other in carrying out fraud. It also said, in such a cases the
transferee would be guilt for liability of double fraud, as he joined transferor
joined in the fraudulent scheme and participated in commission of the transfer
and he committed another fraud by suppressing from the Court the fraudulent
character of the transfer when he made out the claim for the recovery of the
properties conveyed to him. The transfer was not supported by any
consideration and therefore no title is transferred to him.
So in the view of public interests, the Court held that the plea of fraud is
allowed and tried and it is upheld that the estate should lie where it rests.
Notwithstanding the rights of transferor and a benami transferee, if the transfer
was made to defeat the creditors, a creditor himself can ignore a benami

15 (1962) 3 SCR 739.

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transaction and can proceed against the property as it was of the transferor. The
creditor need not have to set it aside under this section because, benami
transaction is not a transfer at all.
We have to note that, whether the transfer is real or sham, it is depended upon
the facts and circumstances in each case. If it is clearly shown that the very
object of the transfer was to defeat the interest of creditors, the transfer can be
avoided by the creditor under this section.
But the present scenario is changed. The Benami Transaction Act, 1988
provides that properties purchased in the name of ostensible owner or
benamidar shall belong to benamidar and real owner cannot claim from him.
This Act now treats benami transfer as a real transfer under which the
benamidar becomes real owner. However, Section 3 of this Act says that the
provisions of Section 53 of TPA or any law relating to transfers for illegal
purposes are not affected.

CHAPTER 5
How Fraudulent Intention in the Transfers Can Be
Proved
Fraudulent intention in transfers must be proved by direct or circumstantial
evidence and every case must be examined in the light of surrounding
circumstances. Some circumstances that give a strong presumption that the
transfer was fraudulent are:
1. The transfer was made in secret and haste.
2. The transfer was made soon after the decree ordering the payment of debt
was passes against the judgment-debtor.
3. The debtor in the case transferred whole of his property without keeping
anything for himself.
4. The consideration paid was very small when compared to the real or
original value of the property transferred.
5. Evidence was shown that there was no actual payment of consideration as
given in the sale deed.
Not only these circumstances, but there are many other circumstances in which
inference of intent to defeat or delay creditors may be drawn. So every case is

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depended upon its own facts and circumstances. It is subject to a matter of fact
that the transfer is bonafide or fraudulent.

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 CHAPTER 6

IF THERE ARE SEVERAL CREDITORS

If there are several creditors, transfer in favor of one creditor does not amount to
an intention to defeat or delay the remaining creditors. Its upon the debtors
discretion to pay his debts in any order of his preference. If A has taken loan
from B, C and D, transfers certain properties to C in satisfaction of the loan
taken from him. This transfer necessarily cannot be considered as a transfer
made to defeat or delay the interest of other creditors. It was happened in the
case of Mina Kumari v. Bijoy Singh 16, the Privy Council held that in the case
there are two or more creditors, the debtor can give preference to any creditor
and can clear his debts in any order he chooses.
Another landmark regarding this context is Chogmal Bhandari v. Deputy
Commercial Tax Officer, Kurnool17. The facts of the case were: A partnership of
two partners was dissolved in 1963. A registered deed of trust was executed by
which the properties were vested in the trustees for purpose of paying off the
creditors. Afterwards a business was started by the grandson of one of the
partners and some provisional assessments were made his name for the years
1966-1969. In 1971, Sales Tax authorities made the assessments in the name of
the Joint Hindu Family for the first time but found that the tax could not be
realized from the assesses on account of the Trust Deed, and therefore, treated
the Deed as void and fraudulent and contended that the assessments were made
to defeat the debts of Sales Tax Department. But in proceedings, these facts
were found. It was found there was no assessment made against the Joint Hindu
Family at the time of execution of Trust Deed. Therefore there was no real debt
due by from one of the executants of the Trust. There was no intention of use of
unlawful purpose by the Trust. In the Trust Deed, the names of the creditors to
whom the debts are to be payable were clearly mentioned. The Trustees did not
keep reserve any advantage for themselves. It was also found that there was no
material to show that the creditors obtained collusive decrees.
Here the question arisen before the Supreme Court was that whether this Trust
Deed was hit by Section 53 of TPA or not. In this context, Supreme Court held
that:-

16 A.I.R. 1916 P.C. 238.

17A.I.R. 1976 S.C. 656.

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Observing the facts and circumstances of the case, it cannot be said that Trust
was executed to defraud the creditors, Sales Tax Department. Under the section
a person must prove two facts to challenge the transaction. Firstly, the document
was executed by settler. Secondly, the said document was executed with a clear
intention to defraud or delay the creditors. It is a matter of the fact that intention
would be proved on the basis of facts and circumstances surrounding the case.
The Supreme Court also held that, it is a well settled that a mere fact that the
debtor chooses to prefer one creditor to the either because the priority of the
date or otherwise by itself cannot be misleaded that it was done to defeat the
other creditors.
In Musahur Sahu v. Hakim Lal18, Kisun Binode and Musahur Sahu were the
debtor and creditor respectively. Musahur Sahu sued the Judgment-Debtor
Kisun Binode for the recovery of his debts in December, 1900. Musahur Sahu
presented a petition for attaching the properties of the debtor as a security. This
petition was filed in January, 1901, when the original suit was during pendency.
In February, 1901, Kisun Binode, the debtor gave an affidavit that he has no
intention to attach any property, accordingly the petition for attachment was
dismissed. But after the petition was dismissed, Kisun Binode sold his
properties to Hakim Lal who was another creditor of him. Then Musahur Sahu,
pleaded that the transfer to Hakim Lal were done do defeat or delay his interest
and therefore it should be held void under Section 53 of TPA and the properties
should not be given to Hakim Lal.
In this case, the appeal was dismissed by the Privy Council, and held that
transfer of property by a debtor to one creditor in preference of the other is not a
fraudulent transfer with the intent to defeat or the delay the interest of another
creditor. The Lordships observed in the case Middleton v. Collak 19, the transfer
if defeats or delays the creditors is not an instrument which prefers one creditor
to another but an instrument which removes a property from the creditors to the
benefit of the debtor. The debtor must not remain any advantage or benefit for
himself. He may one creditor and leave another unpaid. The court further
observed that as soon as it is found that the transfer here impeached was made
for adequate consideration in satisfaction of genuine debts, and without
retaining any benefit to the debtor, it follows that no ground for impeaching it
lies in the fact that the plaintiff who also was a creditor was a loser by a
payment being made to this preferred creditor, there is no question being
bankrupt.

18 (1915) LR 43 IA 104.

19 (1876) 2 Ch D 104.

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 CHAPTER 7

EXCEPTIONS TO SECTION 53(1)

Section 53(1) recognizes two exceptions. The rule that a fraudulent transfer can
be avoided by creditors is not applicable to:
a) A transferee in good-faith and consideration,
b) Any law relating to insolvency for the time being in force.
A transferee in good-faith and consideration:
A transferee is protected if he takes property in good-faith and consideration.
When a transferee purchases a property in good-faith and consideration, the
creditors cannot take benefit of 53(1). Where a transferee has no knowledge i.e.
no actual or constructive notice of the fraudulent intention of the transferor, the
creditors cannot claim the property or avoid the transfer under Section 53(1).
But if the transferee is aware of the fraudulent intent an aim and keeps silent, it
is not be done in good-faith and cannot get the benefit of this exception.
In the case of Vinayak v. Kaniram20, the transferors intention was to convert his
immovable property into cash so as to keep it out of reach of the creditors and
the purchaser was aware of that intention of the debtor. The Court held that the
purchaser was also a party to fraud as he was aware of that fraudulent intention
and sale was voidable at the option of the creditors.
In Kapini Goundan v. Sarangapani21, a man who had taken large sum of money
as loan, transferred his whole property to the children of his first wife in
consideration of her relations allowing him to marry a second wife. In this case,
the Madras court held that the consideration was good and the transfer was not
on the basis of fraudulent intention to keep it away from creditors. It should be
noted that this decision must be regarded as only an exception and should not be
regarded as a general rule.
Therefore, good-faith on the part of transferee is more significant factor in
protection of rights of the transferee than payment of consideration.

20 A.I.R. 1926 Nag. 293.

21 (1916) Mad. W.N. 288

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Any law relating to insolvency for the time being in force:
The rights of the transferee created under the law of insolvency are not affected
by Section 53 even if the transferors intent was to defeat or delay the creditors
interest. The main aspect of the insolvency laws is that the properties of the
insolvent are equally distributed between the creditors. If one creditor is given
preference, then it is deemed to be a fraudulent transfer under this section.
Where the transferor (debtor) has been declared insolvent, and the transferee
purchases such property from him, the transfer cannot be avoided by creditors.
In such cases, the Insolvency Courts are competent here to decide whether the
transfer was voidable under Section 53 of TPA.
Section 53 (2): Gratuitous transfer to defraud subsequent transferee
Section 53 (2) enacts that gratuitous transfer of an immovable property with
intent to defraud a subsequent transferee shall be voidable at the option of
subsequent transferee. This section explains about the situation where an
immovable property is transferred to person without consideration and the same
property is again transferred to another person. So the subsequent transferee has
advantage under this section where he can avoid the first transfer. But in this
case the subsequent transferee should prove that the first transfer was a sham or
fictitious transfer made to defraud him. The general rule is that the first transfer
has advantage or preference over the second and so on, but if the subsequent
transferee proves that the first transfer was fraudulent and it was made to
defraud him, the later transfer would stand valid. It should be noted that this
section only protects the interest of the bonafide transferee and the transfer
should have some value (consideration). The mere fact that the first transfer was
gratuitous and the later transfer was for consideration does not essentially raise
the presumption that the prior transfer was made to defraud. Fraud in the prior
transfer must be fully established by the subsequent transferee.
Under Section 53, the Wakfnama would be voidable only at the option of the
person who was defrauded or delayed. An important fact should be noted that
this section does not violate the rule of Muslim Law.

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 CHAPTER 8
BURDEN OF PROOF
The burden of proof lies on the creditors of the transferor to show that the
transfer was made to defeat or delay the interest of the creditor. In the case of
Chandradip v. Board of Revenue22, the onus to prove the fraud lies on the person
alleging it. But it may be noted that the burden to prove the intention would
largely depend upon the facts and circumstances of each case.

22 A.I.R. 1978 Pat 148.

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 CONCLUSION
Section 53 of Transfer of Property Act, 1882 deals with Fraudulent Transfers.
This section has two sub sections. The first part of this section deals with the
transfer made to defeat or delay the creditors of the transferors and it is voidable
at the option of such creditor. The second part deals with the gratuitous transfers
with intent to defeat or delay the creditors. This section has some exceptions in
respect of the transfers done towards the transferee in good faith and
consideration. But if the transfer is a gift towards the stranger, then the good
faith is irrelevant. The rights of the transferee created under the law of
insolvency are not affected by Section 53 even if the transferors intent was to
defeat or delay the creditors interest. The basis of the section is that one ought
to be just before being generous. This section was made to disallow a person
conveying the properties to keep it away from the creditors. In my opinion, the
laws regarding fraudulent transfers must be made stricter and such transferors or
transferees who committed fraud must be penalized for committing fraud.

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 BIBLIOGRAPHY
BOOKS
Dr.G.P.TRIPATHI ON THE TRANSFER OF PROPERTY ACT, (16th EDITION,
2009).
S.N.SHUKLA ON THE TRANSFER OF PROPERTY ACT, (27 th EDITION,
2009).
MULLA ON THE TRANSFER OF PROPERTY ACT, (10th EDITION, 2006).
Dr. POONAM PRADHAN SAXENA, PROPERTY LAW, (2nd EDITION, 2011)

Dr. AVTAR SINGH, TEXT BOOK ON THE TRANSFER OF PROPERTY ACT,

(2nd EDITION, 2009)
STATUTES

TRANSFER OF PROPERTY ACT, 1882.

ONLINE LEGAL DATABASES

www.manupatra.com

www.westlaw.com

www.scconline.com

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