ASSIGNMENT ON

“INTENTION NOT TO CREATE LEGAL

OBLIGATION”
SUBMITTED TO-- Prof. TANMAY AGARWAL
(FACULTY- LAW OF CONTRACT)

SUBMITTED BY ---
VEDANT VYAS (38)
SEMESTER-II SECTION-A

(B.B.A, L.L.B. HONS.)

BATCH- 2018-23

UNITED WORLD SCHOOL OF LAW, KARNAVATI

UNIVERSITY.

ACKNOWLEDGEMENT
This is not just a ordinary acknowledgement of help that i received but a sincere expression
of gratitude to all those who have helped me to complete this project and made it seem
apparently more readable than otherwise it would have been.

I am in debt to my faculty advisor Prof. Tanmay Agarwal for giving such an interesting and
wonderful topic “Intention not to create legal obligation” and who has been extremely kind to
make space for all my enthusiasm and endeavours and making it seem easy by clearly
explaining its various aspects.

I am also grateful to all my friends and seniors who have given their valuable suggestions
pertaining to the topic and have been a constant source of help and support.

Nikita Tiwari

Vedant vyas
 TABLE OF CONTENTS

Contents
ACKNOWLEDGEMENT ................................................................................................................1
INTRODUCTION ..........................................................................................................................4
CHAPTER- 1 ................................................................................................................................6
CHAPTER-2 .................................................................................................................................7
CHAPTER-3 ...............................................................................................................................11
COMPARISION ..........................................................................................................................14
Compare Balfour v Balfour and Merritt v Merritt ...............................................................14
Balfour v Balfour [1919] 2 KB 571, CA .............................................................................14
Merritt v Merritt [1970] 2 All ER 760, CA .........................................................................14
CONCLUSION ............................................................................................................................14
BIBLIOGRAPHY .........................................................................................................................15
 SIGNIFICANCE OF THE TOPIC

1- If there is no intentions to create legal relations the contract would not be enforceable legal
and binding.
2 -Without intentions to create legal relations the parties cannot sue each other.
3- Without intentions to create relations the contract may lack the binding effect.

AIMS AND OBJECTIVE

1- To know about the intention not to create legal obligations in India.

2- To know about the intention not to create legal obligations in America.
3- To know about the intention to create legal obligations.

LITREATURE REVIEW

There is no provision in the Indian contract act requiring that an offer or its acceptance
should be made with intention of creating a legal relationship But in English Law it is a
settled principle that “to create a contract there must be a common intention of the parties to
enter into legal obligation”. In the case of Balfour vs Balfour it has been show about the
intention not to create legal obligation.

RESEARCH QUESTION

The aspect of the intention not to create legal relationship.

INTRODUCTION

In order that an offer, after acceptance, can result in valid contract, it is necessary that the
offer should be made with an intention to create legal relationship. Promise in the case of
social engagement is generally without an intention to create legal relationship. Such an
agreement, therefore cannot be considered to be a contract. Thus, an agreement to go for
walk, to go to a movie, to play some game, to entertain another person with a dinner cannot
be enforced in a court of law. The test to know the intention of the parties is objective and not
subjective, merely because the promiser contends that there was no intention to create legal
obligation would not exempt him from liability. Case Rose and Frank co. Vs Crompton1 &
Bros. Ltd. And the intention not to create obligation implied from the circumstances of the
case. In the case of Balfour Vs Balfour2 told about the intention not to create legal obligation.
In the social relationship also rule of not to intention create obligation arise but there is
nothing which prevents these persons from agreeing to be bound by their promises.

1
1923 2 KB 261 (CA)
2
1919 2 KB 571
 CHAPTER- 1
The requirement of ‘Intention to create legal relations’ constitutes one of the most significant
conditions of a valid contract in many jurisdictions around the globe—both developed and
developing. Allegedly, Contract Act, being an Act governing relations between private
parties, cannot be interpreted in the court of law without giving much weight age to the
intention of the parties forming such contract. To prove the existence of ‘intention to create
legal relations’ in addition to prove the existence of ‘consideration’ becomes quite
burdensome at times. English Law specifically requires the existence of ‘intention to create
legally binding contract’ for enforcing a contract despite the existence of ‘consideration’ for
the contract. The main argument of this paper is that ‘consideration’ in itself is, and should
ideally be, indicative of such intention. Therefore, as far as common law countries are
concerned, ‘consideration’ in itself should be capable of dealing with the intention of the
parties and there should not be any separate requirement of proving
an ‘intention to create legal relation’.

If there is no intention to create legal relation the contract would not be

enforceable, legal and bind.

“Without intention to create legal relation, the parties can’t sue each other.”
It may cause the contracting party are not legally binding and this circumstance mat the
contract is enforceable. Therefore, the contract is enforceable the contracting party can not
sue each other and the will spoil their business crisis. This will make the contracting parties
hard to enquire their justice.

“Without intention to create legal relation, the contract may become a mere promise.”
In addition with no intention to create legal relations, it will make any contract to become a
mere promise. Mere promise is like a simple promise, arise when there is no intention to
create legal relations. Based on the case of studies the situation of mere promise can be seen
when Nonthan, the comfortable furniture SDN BHD salesman have no intention to create
legal relation. He did not accept case deposits from Mr. John to obey the company policy.
When the mere promise occurs the salesman still can sell the dinning set to other people
because there is no legal contract between Nonthan and Mr. John.

“Without intention to create legal relation the contract may lack the binding effect”
Besides that when there is no intention to create legal relation, it will make a contract or
agreement become unless powerful due to whether one or both of the parties doesn’t have a
consent mind. So if the contract lack of binding effect. It will make difficulty to the party
involved in future.
 CHAPTER-2

Intention to create legal relationship

In order that an offer, after acceptance, can result in valid contract, it is necessary that the
offer should be made with an intention to create legal relationship. Promise in the case of
social engagements is generally without an intention to create legal relationship. Such an
agreement to go for a walk, to go to a movie, to play some game, or entertain another person
with a dinner, cannot be enforced in a court of law. Sometimes the parties may expressly
mention that it is not a formal or legal agreement, whereas in some other cases such an
intention could be presumed from their agreement. The test to know the intention of the
parties is objective and not subjective, merely because the promisor contends that there was
no intention to create legal obligation would not exempt him from liability.
In Rose and Frank co. v. Crompton & Bros. Ltd., the agreement between the parties to the
contract provided that:-
“That arrangement is not entered into……. As a formal or legal agreement, and shall not be
subject to legal jurisdiction in the Law Courts…… that it (the agreement ) will be carried
through by the parties with mutual loyalty and friendly cooperation.
One of the parties made a breach of this agreement. In an action by the other party to enforce
the agreement, it was held that since by the agreement had provided that it was not a formal
or legal agreement, the same was not enforceable

There is no provision in the Indian Contract Act requiring that an offer or it’s acceptance
should be made with th intention of creating a legal relationship. But in English Law it is a
settled principle that “to create a contract there must be a common intention of the parties to
enter into legal obligation”3. It was pointed out in an early case that “contract must not be the
sports of an idle hour, mere matters of pleasantry, never intented by the parties to have any
serious effect what so ever”4. It is not every loose conversation that is to be turned into a
contract, although the parties may seem to be agree5.
LORD ATKIN explained the principle thus, there are agreement between parties which donot
result in contract within the meaning of that term in our law. The ordinary example is where
two party agree to talk a walk together, or where there is an offer and acceptance hospitality.
Nobody would suggest in ordinary circumstances that these agreement result in what we
know as contract, and one of the most usual forms of agreement which does not constituent a
contract appears to be arrangement which are made between husband and wife. These
arrangement do not result in contract at all, even though there may be what would constituent
consideration for the agreement. “There are not contract because parties did not intent that
they shall be attended by legal consequence,” – Balfour v. Balfour.

FAMILY AND SOCIAL MATTERS

The intention of the parties naturally to be a ascertained from the terms of the agreement and

3
ATKIN J at p.293 in rose and frank co. v J.R. Crompton and bros ltd. 1923 2 KB 261 (CA)
4
Dalrymple v dalrymple 1811 161 ER 665, per lord STOWELL
5
Costigan, CASES ON CONTRACT, (third edition) 32.
the surrounding circumstances. It is for the court in each case to find out whether the parties
must have intented to enter into legal obligations. “In the case of arrangements regulating
social relations it follows almost as a matter of course that the parties do not intent legal
consequences to follow. In the case of agreement regulating business relations it equally
follows almost as a matter of course that the parties intended legal consequences to follow6.
This does not, however, mean that in family or social matters ‘there cannot be a legally
binding contract’. All that the law requires is that the parties must intent legal consequences
McGregor v McGregor7 is an early in illustration of a binding engagement between a
husband and wife. Here husband and wife withdraw their complaints under an agreement by
which the husband promised to pay her allowance she was to refrain from pleading his credit,
the agreement was held to be a binding contract. An agreement between relatives to share a
house husband held to be binding8. The principle applies to dealing with other relations, such
as father and son and daughter and mother. These words occur in the judgement of
DANCKWERTS LJ in JONES v PADAVATTON9. A divorced woman was living in
Washington with her son where she was employed as an assistant accountant in the Indian
Embassy on attracting terms. Her mother was in Trinidad and wished her daughter to be near
her. She was particularly attached to the grandson. The mother persuaded her daughter much
against her will to leave service, to take legal education in England and finallg come back to
Trinidad as a practing lawyer. The mother undertook to foot the expenses. Subsequently, the
mother bought a house in England, part of which was allowed to the daughter and rest tented
out. For five long years the daughter could not complete her education. She also remarried in
the mean time. Differences arose between them and the mother stop payments and also
commenced proceeding to evict the daughter.
DANCKWERTS LJ allowed the mothers appeal. His lordship said: “there is no doubt that
this case is a most difficult one, but.... is one of those family arrangements which depend on
the good faith of the promise which are made and are not intended to be rigid, agreements.’
SALMON LJ also allowed the mother’s appeal, but on a different ground. He felt that acting
on her mother promise, the daughter had left an attractive service and gone to another country
for an education and the mother could not in these circumstance get out of the promise at her
sweet will and leave the daughter in that condition. The engagement, did result a contract, but
the agreement could last only for a period of five years was more then sufficient for the
purpose. She could not have expected her mother to support her, her son and her husband in
perpetuity.
The mere opening of a joint banking account between a man and his wife or the man
promising to buy her a car in an effort to improve strand matrimonial relationship has been
held to be a purely domestic arrangements not resulting in any legal relationship10.

OBJECTIVE, NOT SUBJECTIVE, TEST OF CONTRACTUSL INTENTION.

The test of contractual intention is objective not subjective. What matter is not what the party

6
per BANKES LJ at p.282 rose and frank co. v J.R. Crompton and bros ltd, (1923) 2 KB 261 (CA)
7
(1888) 21 QBD 424 (CA) . see also pearce v merriman, (1904) 1 KB 80
8
Parker v clark, (1960) 1 ALL ER93: (1960) 1 WLR 286
9
(1969) 1 WLR 328..(1969) 2 ALL ER 616 at p.620 (CA)
10
See at p.623,supra and Spellman v Spellman, (1961) 1 WLR 921: (961) 2 ALL ER 498 (CA)
had in mind, but what a reasonable person would think, in the circumstances, there intention
to be. Thus, where three ladies, to of them being a mother and daughter and the third a paying
guest, together made entries into a crossword puzzle in the name of the mother, the expenses
being met by one or other, without any rule. The entry was successful and the mother refused
to share the price. But the court held that she was bound to do so, for any reasonable man
looking at their conduct would at once conclude that they must have intended to share the
price11. Following these principles, the Supreme Court observed on the facts of the case:
Here, one partner has lent a large some of money to the other to be utilized as capital in a
partnership venue. The transaction is in the context of a commercial venture. The
presumption is that legal obligations are intended. The onus is on the parties asserting the
absence of legal obligation and the test is not subjective but is an objective one where, as
here, the text implications of large financial obligation are sought to be put an end to, the
burden is heavy on the assesses to establish that what would otherwise be the incidence of the
transaction where excluded from by the parties12.
The court sited the following passage from an English case
in deciding whether or not there was any contract in relations to a certain transaction or
whether or not sufficient notice of a certain term was given, the law applies as an objective
and not a subjective test.... in the absence of such evidence how can the court assume that the
master did not intent to enter into a contract.
The result of case on this subject are bound to be variable, for the matter wholly depends
upon the fact whether the conduct of the parties in the surrounding circumstance affords
evidence of objective intention. For example, in Merrit v Merrit13 an agreement to transfer to
the wife the beneficial ownership of the matrimonial home at the time of separtion was held
to be binding. But in Gould v Gould14, an agreement simply made was held to be not binding
as the husband undertook to pay only as long as he had the means to pay. Uncertainty of
these words shoed that “no legal relations where there”.

BUSINESS MATTERS
In an agreement, to provide loan facilities to a company’s subsidiaries, the company gave to
the lender assurance of providing security by giving them two letter “of comfort”, they being
commercial papers where held sufficient to create the responsibility of providing security.
Taking into account the nature of the promise, the court held ”a letter of comfort from a
parent to a lender stating that it was the policy of parent’s company to ensure that it’s
subsidiaries was ‘at all times in a position to meet its liability’ in respect of a loan made by
the lender to the subsidiaries did not have contractual effect if it was merely a statement of
present fact regarding the parents company intentions and was not a contractual promise as to
the parent company’s future conduct. On the facts, the relevant para of the letters of comfort
was in terms a statement of facts and not a promise as to future conduct and in the context in
which the letters were written was not intended to be anything other then a representation of

11
Simpkins v Pays,(1955) 1 WLR 975: (1955) 3 ALL ER 10
12
CWT v Abdul Hussain Mulla Muhammad Ali, (1988) 3 SCC 562, per VENKATACHALIAH J.
13
(1970) 1 WLR 211: (1970) 2 ALL ER 760 (CA), noted, (1970) 1860 LQR 436 at p.437.
14
(1970) 1 QB 275: (1969) 3 WLR 490: (1969) 3 ALL ER 728 (CA). criticized (1970) JBL 113
fact giving rise to no more than a moral responsibilities on the part to meet M’s debt15. And
investment in a partnership firm was taken by the supreme court to be of commercial nature
putting the on us. On the part asserting that he didnot intend to be a legal patner to proof that
fact16.
Even in business matters party intend to rely on each other’s good faith and honour, and not
on the courts. For example. Rose and Frank co. v JR Coopation and bros ltd17.
and executive agreement was drawn between one American and two English firms for their
dealing in paper tissues. The agreement contain the following clauses: “This arrangement is
not entered into as a formal legal agreement and shall not be subject to a legal jurisdiction in
the law of courts either in the US or in England”. The agreement was terminated by one of
the parties contract to it’s terms. The American firm brought an action for the breach. It was
held that the document didnot constitute a bonding contract as there were no intention to
effect legal relations.

SUPREME COURT’s VIEW OF REQUIREMENT OF INTENTION

The Supreme Court has expressed it’s reservation about the need of this
separate requirement of ‘intention to contract’ under the contract act. Going by
the criticism which is already there in the west, the court found that it was a
necessity of those system where consideration was not a requisite of
enforceability. Thus it is still an open question whether the requirement of
‘intention to contract’ is applicable under the contract act in the way in which it
has been developed in England18.
But earlier to this, a limited recognization of the applicable of this principle in
India could be inferred from the decision of the Supreme Court in Banwari lal v
Sukhdarshan Dayal19. In an auction sale of plots of land, a loud speaker was
spelling out the terms, etc. Of the same, one of the statement being that a plot of
certain dimensions would be reserved for a dharamshala. Subsequently, the plot
was sold for private purpose. The purchases sought to restrain this.
Chandrachud J said: microphones.... have not yet acquired notoriety as carry of
binding representation. Promises held out over loud speaker are often claptraps
of politics. In the instant case. The announcement was, if at all, a puffing up of
property put up for sale .
In the subsequent case20 on the subject, the supreme court noted the general
proposition that in addition to the existence of an agreement and the presence of

16
CWT V Abdul Hussain Mulla Muhammad Ali (1988) 3 SCC 562,568
17
(1920) 2 KB 261 (CA)
18
CWT v Abdul Hussain Mulla Muhammod Ali,(1988) 3 SCC 562 at p.569.
19
(1973) 1 SCC 294.
20
CWT v Abdul Hussain Mulla Muhammad Ali,(1988) 3 SCC 562 at p.569
consideration that there is also a contractual element in the form of the intention
of the parties to create legal relation, and also noted that these propositipon,
though accepted in englisgh law, has not passed unchanllenged. The court then
sited the following passage from Cheshire and Fifoot’s law of contracts: ‘... the
criticism of it made by prof. Wisston demand attention, not only as imanating
from a distinct American jurist, but as eliminating the whole subject. In his
opinion, the separate element of intention is foreign to the common law,
imported from the content by academics influence in the 19 th century and useful
only in systems which lack the test of consideration to enable them to determine
the boundaries of contract”.
Letters of intent
A letter of intent merely indicates a party’s intention to enter into a contract on
the line suggested in the letter. It may become a prelude to a contract. However,
where a letter stated it would be followed by a detailed purchase order which
carried an arbitration clauses, it was held that the letter was not a supply order
and the arbitration clauses contained in it did not by itself fructify into an
arbitration agreement.

CHAPTER-3

CASE LAWS
21
1.Balfour v Balfour

Facts: The Plaintiff and the Defendant were a married couple. The Defendant husband and
the Plaintiff wife lived in Ceylon where the Defendant worked. In 1915, while the Defendant
was on leave, the couple returned to England. When it was time to return to Ceylon, the
Plaintiff was advised not to return because of her health. Prior to the Defendant returning, he
promised to send the Plaintiff £30 per month as support. The parties" relationship
deteriorated and the parties began living apart. The Plaintiff brings suit to enforce the
Defendant’s promise to pay her £30 per month. The lower court found the parties"
agreement constituted a contract.

Issue: Does the husbands promise to pay £30 per month constitute a valid contract which can
be sued upon?

21
Balfour v Balfour (1919) 2 KB 571
Held : The court first recognized that certain forms of agreements do not reach the status of a
contract. An agreement between a husband and wife is often times such a form of
agreement. In such agreements, one party is give a certain sum of money on a daily, weekly,
monthly, etc.. basis. This agreement is sometimes termed an allowance. However, these
agreements are not contracts because the "parties did not intend that they should be attended
by legal consequences." One reason the court is hesitant to treat these agreements as
contracts, is that there would not be enough courts to handle the volume of cases. Thus, here,
the husband’s promise did not rise to the level of a contract.

2. Merritt v Merritt22

Husband agreed to transfer home to wife on separation; whether intention to create legal
relations

Facts: Mr and Mrs Merritt married in 1941. They held their matrimonial home in joint
names. In 1966 Mr Merritt left the family home to live with another woman. Mr Merritt
agreed to pay Mrs Merritt £40 per month. At Mrs Merritt’s request, he signed a document
confirming that when she had repaid the balance on the mortgage, he would transfer the
matrimonial home into her sole name. Mrs Merritt paid off the mortgage and successfully
acquired a declaration that the house belonged to her. Mr Merritt appealed.

Issues: Mr Merritt contended the agreement was a domestic arrangement between husband
and wife and there was no intention to create legal relations and, as such, there was no
enforceable contract. He also argued the purported contract was insufficiently certain to be
enforceable by the court, and that Mrs Merritt had failed to provide consideration for his
promise. Mrs Merritt argued that given they were in the process of separating, the
presumption of there being no intention to create legal relations did not apply. She claimed
there was every intention of creating legal relations, and her having paid off all the expenses
on the home and finishing off the mortgage payments amounted to consideration.

Held: Mr Merritt’s appeal was unsuccessful. When parties are in the process of separating, or
are separated, the presumption of there being no intention to create legal relations does not
apply. The arrangement was sufficiently certain to be enforceable, and the paying of the
mortgage was ample consideration for Mr Merritt’s promise. Mrs Merritt was entitled to the
matrimonial home entirely.

3. Jones v Padavatton23

Agreement for mother to maintain daughter; whether intention to create legal relations

Facts: A mother and daughter came to an arrangement whereby the mother agreed to
maintain her daughter if she agreed to study for the bar. The daughter commenced her studies
and the mother paid her an allowance. The arrangement was later altered and the mother
agreed to provide a house in which her daughter could reside whilst she studied. Mother and
daughter fell into dispute as to the occupancy of the house, and the mother sought possession.
It was held the daughter was entitled to remain in possession and the mother appealed.

22
Merritt v Merritt,(1970) 1 WLR 211: (1970) 2 ALL ER 760 (CA)
23
Jones v Padavatton,(1969) 1 WLR 328 (1969) 2 ALL ER 616 (CA)
Issues: The daughter argued the agreement between herself and her mother amounted to a
legally binding contract and, as such, she should be entitled to remain in occupation of the
house. She claimed there had been an intention to create legal relations and she had provided
consideration for her mother’s maintenance by studying for the bar. The mother argued there
was merely an informal family arrangement, there had been no intention to create legal
relations and she was, therefore, entitled to recover possession of the house. Even if there was
an enforceable contract, she asserted the terms of the arrangement were too vague for the
court to enforce.

Held: The mother’s appeal was successful and she was awarded possession. There is a
presumption that family arrangements are based on mutual trust, family ties and affection,
and that there is no intention to create legally binding contracts capable of enforcement in the
courts. This presumption can be rebutted, but the lack of formality regarding the agreement
between mother and daughter strongly indicated there was no such intention and the daughter
had no defence to her mother’s claim for the house.

4. Banwari lal v Sukhdarshan Dayal24

Facts: 1. Plot No. 765 of Mauza Bhaunjar, Tehsil Ghaziabad->sub-divided by the co-
ownersinto small plots(Chandrapuri Colony).
2.Plot No. 19 was to be reserved as a Dharmshala and yet it was sold to one ManohariDevi
who in turn sold it to the defendant.
3.The defendant constructed a boundary wall around the plot, rendering impossiblethe use of
the plot for common benefit
.4.Plaintiff on behalf of the various purchasers of the sub plot asked for a
declaration that plot No. 19 was earmarked for a Dharmshala, for a permanent injunction
restraining the defendant from interfering with the construction of aDharmshala
and for possession of the plot after demolition of the boundary wall.

Arguments:-Banwari Lal under Order 1, Rule 8 of the CPC;on behalf of other sub plot
owners fileda suit in Trial Court.
Appellant-The defendant constructed a boundary wall around the plot, rendering impossible
the use of the plot for common benefit. Plaintiffs therefore asked for a declaration that plot
No. 19 was earmarked for a Dharmshala, for a permanent injunction restraining the
defendant from interfering with the construction of a Dharmshala and for possession
of the plot after demolition of the boundary wall.
Defendant denied that plot No. 19 was reserved for the use of a Dharmshala and contended
that Manohari Devi who, under the sale in her favour had become an absolute owner of the
plot was entitled to sell it to him.
Judgement: Supreme Court- In the first two courts, arguments revolved round a plea of
estoppels. Besides, estoppel is but a rule of evidence and except in cases like those under
Section43 of the Transfer of Property Act, when a grant is fed by estoppel, the rule does not
operate to create interest in property regarding which the representation is made.
Accordingly, we confirm that judgment and dismiss the appeal with costs.

24
Banwari Lal v Sundarshan Dayal,(1973) 1 SCC 294
 COMPARISION

Compare Balfour v Balfour and Merritt v Merritt

Balfour v Balfour [1919] 2 KB 571, CA
D is a civil servant in Ceylon he was about to return to work, leaving his wife of phosphorus
in the UK. P agreed to pay 30 pounds per month until he returned to her agreement to support
his appeal that no other repair own exchanges. They later divorced and P sought to enforce
D’s promise. The Court of Appeal said that although the P’s commitment to consider, there is
no contract. There are many agreements, said Atkin LJ, including most of the agreement
between husband and wife, both of which had never intended, they may be prosecuted. If
these agreements are completely outside the field of contract.

Merritt v Merritt [1970] 2 All ER 760, CA

A husband leaves his wife lived with another woman. H agreed to pay £ 40 a month, they do
a written agreement, in return for their W jointly owned mortgage the house to consider, H
would transfer to her sole ownership. Court of Appeal upheld the ruling Stamp J, which is a
legally enforceable contract. In this case, Lord Denning MR said, the court looked at the
situation they are placed, and asked whether reasonable person would think you want to tie
an agreement.

CONCLUSION

All in all, it does comes to light that in respective of the contractual provisions which persist
in various countries: the element of consideration in India finds itself sufficient to envisage
per se the intention of the contracting parties to enter into a legal relationship.
 BIBLIOGRAPHY

1. List of Cases
 Balfour v Balfour
 Merritt v Merritt
 Jones v Padavatton
 Banwari Lal v Sukhdarshan Dayal
2. Books Referred
 Contract and Specific Relief by Avtar Singh
 Contract-I by R.K Bangia
 The Indian Contract Act by MULLA
3. Websites
 www.lawteacher.net
 www.indiankanoon.org
 www.casebrief.com
 www.researchgate.net