JITENDRA CHAUHAN COLLEGE OF LAW

Critical Analysis of Doctrine of Frustration – Contract Law- 1

(FY LLB 2019-20)

Submitted to Prof. Poorva Dighe

Submitted by Akshat Tiwary (D-210)
 TABLE OF CONTENTS

SERIAL TOPIC PAGE NO

NO
1. Aim & Object 3

2. Research Question 3
3. Introduction 4

4. Emergence of Doctrine of Frustration 5

5. Impossibility of performance 6

6. Application of Doctrine of Frustration 7

7. Effect of frustration 9

8. Conclusion 13

9. Bibliography 14

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LIST OF CASES

SERIAL TITLE CITATION

NO
1. Charan lal Jain v Arun kumar Jain AIR 1979 Del 188

2. Denny,Mott and Dickson Ltd v B Foster and Co Ltd (1944) AC 265

3. Joseph Constantine construction co Ltd v Imperial 1942AC 154

Smelting Crop
4. Krell v Henry 1903 2 KB 740

5. Paradise v Jane (1647) 2 ER

6. Robinson v Davinson (1871) L.R. 6 EX.

269

7. Reiley v The King (1934) AC 265

8. Satyabarta Ghosh v Mugneeram AIR 1954 S.C. 47

9. Taylor v Codwell Q.B.(1863)

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Aims & Object
The aim of the project is to have deeper and detailed understanding of the Doctrine of
Frustration and its application under India law.

Research Question
1. How did the Doctrine of Frustration emerge?
2. What is the Impossibility of Performance?
3. Explain the Application of the Doctrine of Frustration?
4. What are the effects of the Doctrine of Frustration?

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INTRODUCTION
The Indian Contract Act is a very important act with regards to the regulation of contract law
in India. The act is based on the principles of English Common Law. The Indian Contract
Act, 1872, extends to the whole of India, except the state of Jammu and Kashmir 1and came
into force on 1st September, 1872.

An agreement enforceable by law is contract 2, the object of which is to create an obligation.

Contract results from a combination of two ingredients- agreement and obligation. All
agreements are contracts, if they are made by the free consent of parties competent to
contract, for a lawful object, and are not expressly declared to be void.3

Chapter IV of the act which includes sections 37 to 67, deals with various rules as to the
performance of contracts. Section 37 to 39 forms the Obligation of Parties to perform
Contracts. Section 40 to 45 includes By whom Contracts must be performed. Section 46 to 50
and 55 describes the rules for Time, Place and Manner of Performance. Performance of
Reciprocal Promises comes under Section 2, 51-54 and 57. Performance of Alternative
Promises forms Section 58. Section 59-61 includes Rules as to Appropriation of Payments.
Section 37-39,56,62-64 and 67 describes the rules as to Modes of Discharge of Contracts.

Discharge of Contract are those contract which need not be performed. According to Indian
Contract Act, these are the following ways that a contract may be discharged:

 By Performance
 Performance is dispensed with or excused under Section 37
 When one party refuses offer of performance under Section 38
 When one party refuses to perform the promise wholly4
 Under Section 56, agreements to do impossible act is void
 Under Section 63, by waiver, accord and satisfaction
 By rescission of a voidable contract under Section 64
 Negligence of Promisee to afford Promisor reasonable facilities for performance5
 By operation of law

The Doctrine of Frustration comes under the section 56 of Indian Contract Act,1852. It states
that any act which was to be performed after the contract is made, becomes unlawful or
impossible to perform, and which the promisor could not prevent, then such an act which
becomes impossible or unlawful, will become void.

Emergence of the Doctrine of Frustration

1
Subs. By Act 3 of 1951, sec and Sch., for “except Part B states”
2
Section 2 (h) of Indian Contract Act.
3
Section 10 of Indian Contract Act.
4
Section 39 of Indian Contract Act.

5
Section 67 of Indian Contract Act.

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The origin of Doctrine of Frustration has been, just like many other laws, from the Roman
laws. It was part of the Roman contract law which extinguished obligations of innocent
parties where the thing is destroyed without the debtor’s act or default, and the contract
purposes has ceased to be attainable. It was applied to save, from liability, a man who
promised to deliver a slave by a certain day, if the slave died before delivery.

In England, before 1863, it was general rule of law of contract that a person was absolutely
bound to perform any obligation which had been undertaken, and could not claim to be
excused by the mere fact that performance had subsequently become impossible; for ‘where
there is a positive contract to do a thing, not in itself unlawful, the contractor must perform it
or pay damages for not doing it, although in consequence of unforeseen accidents, the
performance of his contract has become unexpectedly burdensome or even impossible.6

In the case of Paradise v Jane7 (1647) P sued j for rent due upon a lease. J pleaded that a
certain German Prince, by name Prince Rupet, an alien born, enemy to the king and kingdom,
had invaded the realm with a hostile army of men; and with the same force did enter upon the
defendant’s possession, and him expelled, and held out of possession…whereby he could not
take the profit. This plea was in substance a plea that the rent was not due because the lessee
had been deprived, by events beyond his control, of the profits which the rent should have
come.

The court held that this was no excuse. When the party by his own contract creates a duty or
charge upon himself, he is bound to make it good. If he may, notwithstanding any accident by
inevitable necessity, because he might have provided against it by his contract, and therefore
if the lessee covenant to repair a house, though it be brunt lighting, or thrown down by
enemies, yet he ought to repair it.

It was the case of Taylor vs. Caldwell8 in which the “rule is only applicable when the contract
is positive and absolute, and not subject to any condition either expressed or implied”. The
fact of the case is that the defendants had agreed to let the plaintiffs the use of their music hall
between certain dates for the purpose of holding a concert there. But before that first day on
which a concert was to be given, the hall was destroyed by fire without the fault of either
party. The plaintiff sued the defendants for their loss. It was held that the contract was not
absolute, as its performance depended upon the continued existence of the hall. It was,
therefore, “subject to an implied condition that the parties shall be excused in case, before
breach, performance becomes impossible from the perishing of thing without default of the
contractor.”

 Thus, the doctrine of frustration comes into play in two types of situation, first, where the
performance is physically cut off, and, second, where the object has failed.

Impossibility of performance
6
Channel island ferries ltd v sealink UK Ltd(1988)
7
[1647] EWHC KB J5
8
QUEEN’S BENCH,(1863) 3 B &S 826

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Impossibility of performance is two kinds

Initial impossibility

Section 56 first lays down the simple principle that “an agreement to do an act impossible in
itself is void.” For example, an agreement to discover a treasure by magic, being impossible
of performance, is void.

Subsequent impossibility

Sometime the performance of a contract is quite possible when it is made by the parties. But
some event subsequently happens which render its performance impossible or unlawful. In
either case contract become void. For example after a contract of marriage, one of the parties
goes mad, or where the contract is made for import of goods and import is thereafter
forbidden by a government order, or where a singer contract to sing and become too under
the ill to do so, the contract in each case becomes void9. A contract is deemed to have been
become impossible of performance and, thus, void following circumstances

 Destruction of the subject matter of the contract;

 By death or permanent incapacity of the parties (like insanity) where the contract is
personal in nature;
 Supervening impossibility or illegality, involving actions contrary to law or public
policy;
 Outbreak of war, war restrictions (avoidance of trading with alien enemy, and so on);
 Imposition of government restriction or orders or acquisition by government; and
 Non-existence or non-occurrence of a particular state of things.

Frustration may be defined as the occurrence of an intervening event or change of

circumstances so fundamental as to be regarded by the law both striking at the root of the
agreement, and as entirely beyond what was contemplated by the parties when they entered
into the agreement. If an event which could not be foreseen by both parties supervenes,
frustration would apply. Section 56 of the Indian Contract Act, 1872 does not deal with the
cases in which an event, the parties took it for granted will never happen does happen and
makes the performance of the contract impossible. If it be held that this Section is exhaustive,
no relief can be granted to any of the parties on the happening of such an event, but this
would be against the very principle underlying the Section.

If the inability to perform the contract is due to the fault of one of the parties, he cannot
successfully plead frustration. It is also true that if the parties expressly contract with
reference to the occurrence of the supervening events, frustration is inapplicable. But there is
another type of case outside these rules. The parties when they made the contract, may have
foreseen the supervening event as probable, but may have made no express provision with
respect to it. Here, if such event occurs, frustration can be pleaded.

Application of doctrine of frustration

9
Chaman lal Jain v Arun Kumar Jain AIR 1996 Del 188

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A contract may be frustrated if it becomes impossible to perform or if the purpose of the
agreement becomes frustrated or if the performance becomes illegal. The doctrine of
frustration of contract is applicable to a range of contracts. It is therefore, not possible to lay
down an exhaustive list of situation in which the doctrine is going to be applied so as to
excuse performance. The law upon the matter is undoubtedly in process of evolution 10.The
following grounds are-

Destruction of Subject-Matter

The doctrine of impossibility applies with full force where the actual and specific subject
matter of contract has ceased to exist ‘Taylor v Coldwell’11’ is the best example of this class’.
There, a promise to let out a music hall. The another case is ‘Howell v Copland’. The
defendant contracted to sell a specified quantity of potatoes to be grown on his farm, but
failed to supply them as the crop was destroyed by a disease.

Change of circumstances

A contract will frustrate, ‘’where circumstances arise which make the performance of the
contract impossible in the manner and at the time contemplated. 12 The Punjab High Court in
Pameshwari Das Mehra v Ram chand13 explained the principle thus.’’ It is clear that if there
is entirely unanticipated change of circumstances has affected the performance of the contract
to such as extent as to make it virtually impossible or even extremely difficult or hazardous.
If that be the case, the change of circumstances not having been brought about by the fault of
either party, the court will not enforce the contract.

In this case, A contracted to supply to B certain classes and qualities of American piece
goods. The contract was Karachi. The goods arrived there after some delay. B refused to
accept on the ground that both the qualities and quantities offered for delivery were not
according to the particular contract. A called upon B to refer the dispute to the nominated
arbitrator who was residing at Karachi. Then came partition which made it impossible for
non-Muslims go to Karachi. Holding that the contract was not thereby frustrated, the court
said ‘’If it was necessary for the parties to go to Karachi and to take witness there, the
performance of the arbitration agreement would have rendered impossible. But, as going to
Karachi was not necessary, 7the change of circumstances did not have a material effect on the
contract’’

In the case of Joseph Constantine construction co ltd v Imperial smelting corpn 14, where a
ship was chartered to load a cargo but on the day before she could have proceeded to her
breath, an explosion occurred in the auxiliary boiler, which made it impossible for her to
undertake the voyage at the scheduled time, the House of Lords held that frustration had, in
fact, occurred in the circumstances.
10
A.L.Corbin Recent development in contracts (1937)
11
(1863)3 BS 826;122 ER 309
12
Viscount Maugham in joseph Constantine line ltd v imperial smelting corpn, 1942AC 154(1941)2All ER 165
(HL)
13
AIR 1952punj 34,38
14
1942 AC154(1941)2All ER

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Non- occurrence of particular event

The principal of frustration has also been held to apply to cases concerning of an expected
event. In Krell v Henry15, the defendant was to hire from the plaintiff a flat for June 26 and
27, on which days it had been announced that the coronation procession would pass along
that place. A part of the rent was paid in advance, but the procession was cancelled owing to
the illness of the King, the defendant refused to pay the balance. It was held that the real
object of the contract, as recognised by both contracting parties, was to have a view of the
coronation procession, which therefore, became the foundation of the contract. The object of
the contract was frustrated by non-happening of the coronation and the plaintiff was not
entitled to recover the balance of the rent.

Death or incapacity of Promisor

Where performance of obligation under a contract for the personal service is rendered
impossible or radically different by the death or incapacitating illness of the promisor, the
contract will be frustrated. In Robinson v Davinson16 in this case D’s wife an eminent piano
player, perform at a concert but was prevented from doing so by a dangerous illness. An
action was brought against D claiming damages for breach of contract. It was held that the
contract was discharged by D’s wife illness, and it was not therefore broken by her failure to
perform, nor on the other hand, could she have insisted on performing when she was unfit to
do so, as frustration is not brought about by an act of election. These are example of cases
where performance by relevant party is personal and cannot be carried out by anyone else so
that death or illness gives rise to frustration.

Change in the law

The performance of contract may be made legally impossible either by a change in the law or
by a change in the operation of the law by reason of new facts supervening. The law may
actually forbid the doing of some act undertaken in the contract;17 or not to act in a certain
way, as for example where a price for land subject to a restrictive covenant against building is
compulsorily acquired and built upon by act of parliament. Such cases are explained by the
policy and elementary; proposition that if the further performance of a contract becomes
impossible by legislation having that effect is discharged.18

Outbreak of War

The outbreak of war is another event which, by changing the operation of the law, may have
the effect of abrogating obligation outstanding under a contract by reason of supervening
illegality, if one of the parties resides in this country and the other in enemy or enemy
occupied territory, and the contract is one which involves dealing with the enemy. So strong

15
(1903) 2KB 740(1900-3)All ER Rep 20(CA)
16
(1871) L.R. 6 EX. 269
17
Denny, Mott and Dickson ltd v B Foster and Co Ltd(1944) AC 265

18
Reilly v The King (1934) AC 176, 180

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is public policy consideration in this situation that the contract will be wholly frustrated, even
though the parties themselves provide that their obligations shall be merely postponed.19

Compensation for Loss through Non-Performance of Act known to be Impossible or

Unlawful

When the Promisor has promised to do something which he knew, or with reasonable
diligence, might have known, and which the promise did not know to be impossible or
unlawful, such promisor must make compensation to such promise for any loss which such
promise sustains through non-performance of the promise. For example, A contracts to marry
B, while being to married to C, and being forbidden by the law to which he is subject to
practice polygamy. A must make compensation to B for the loss caused to her by the non-
performance of his promise. In such cases, there is an element of fraud.

Effects of frustration

"It is well-settled that if and when there is frustration the dissolution of the contract occurs
automatically. It does not depend on the grounds of repudiation or breach or the choice or
election of either party. It depends on the effect of what has actually happened on the
probability of performing the contract."20

Frustration should not be Self-induced Effects of frustration

Explaining the principle that frustration should not be self-induced, Lord WRIGHT said in
Maritime National Fish Ltd v Ocean Trawlers Ltd 21 that the essence of 'frustration' is that it
should not be due to the act or election of the parties. Frustration should arise without blame
or fault on either side. Reliance cannot be placed on a self-induced frustration. The facts
were: The appellants hired the respondents' trawler, called The St Cuthbert to be employed in
fishing industry only. Both parties knew that the trawler could be used for that purpose only
under a license from the Canadian Government. The appellants were using five trawlers and,
therefore, applied for five licenses. Only three were granted and the Government asked the
appellants to name the three trawlers and they named trawlers other than The St Cuthbert.
They then repudiated the charter and pleaded frustration in response to the respondents'
action for the hire.

The Judicial Committee of the Privy Council held that the frustration in this case was the
result of the appellants' own choice of excluding the respondents' ship from the license and,
therefore, they were not discharged from the contract.22

In another similar case, the contract was to export 1500 tons of sugar beet pulp pellets with a
further option for the same quantity. The sellers obtained an export license for 3000
tons.They also contracted with another buyer to supply him 1500 tons. But the Government
19
Ertel Biber and Co Rio Tinto co ltd
20
Per Lord Wright in Denny, Mott & Dickson Ltd v James B. Fraser & co Ltd, 1944 AC 265: (1944) 1 All ER
678 (HL).
21
1935 AC 524: 1935 All ER Rep 86
22
Followed in India in Jawala Prasad v Jawala bank Ltd AIR 1957 SC 1956

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refused to grant any further license. They shipped the whole agreed quantity to the first
buyer.23 They were now left with the export license for 1500 tons only, but were under two
obligations, one to supply 1500 tons to the first buyer under the option given to him, and
another, with the second buyer for the same quantity. As a face-saving device they
apportioned the supply between the two buyers giving about half to either. The second buyer
sued for breach of contract.24 The suppliers pleaded frustration. They were held liable.

Frustration Operates Automatically

Frustration operates automatically to discharge the contract "irrespective of the individuals

concerned, their temperaments and failings, their interest and circumstances. The legal effect
of frustration does not depend on their intention or their opinions, or even knowledge, as to
the event.25" This is particularly true of Indian law as Section 56 of the Contract Act lays
down a rule of positive law and does not leave the matter to be determined according to the
intention of the parties. A subsequent case, however, shows that in certain circumstances
frustration may be waived by one party and then the other will be bound by the contract. In H
R &. S Sainsbury Ltd v Street:26

There was the sale of 275 tons (5% more or less) of feed barley to be grown on seller's land.
The crop amounted to only 140 tons. The seller resold it to another and contended that he had
the right to do so because the contract had ended by frustration. But he was held liable for
breach of contract. There was Frustration only to the extent of crop failure. The buyer could
waive it and claim delivery of whatever little crop the seller's land had produced.27

The Supreme Court has laid down that frustration puts an end to the liability to perform the
contract. It does not exterminate the contract for all purposes. For example, whether the
doctrine of frustration would apply or not has to be decided within the framework of the
contract and, if the contract contains an arbitration clause, the arbitrator could decide the
matter of frustration.28

Adjustment of Rights (Restitution)

The rights of the parties are adjusted under Section 65. Obligation of person who has received
advantage under void agreement or contract that becomes void. — When an agreement is
discovered to be void, or when a contract becomes void, any person who has restore it, or to
make compensation to it, to the person from whom he received it.

The effect of the principle laid down in the section is that when the parties have entered into
an apparently valid contract and some benefits have been passed under it, and subsequently
the contract is either discovered to be void or becomes void, the party who has received the
23
Satyabrat Ghose v Mugneeram Bangur and Co AIR 1954 SC 44
24
Maritime National Fish Ltd v Ocean Trawlers Ltd, 1935 AC 524 ALL ER REP 86 (PC)
25
LORD LoREBURN in Davis Contractors Ltd v Fareham Urban Distt Council 1956 AC 696
26
(1972)1 WLR 834
27
G.D. Goldberg ,Is Frustration Invariably automatic (1972)88LQR 464
28
Nihati Jute Mills v Khyaliram Jagannath AIR 1968, SC 522 (1968)

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benefits must restore them to the other29. The section does not apply to a contract which the
parties knew at the time of making it to be void. The section also does not apply to a case
where the benefits are being passed at a time when the contract had, though unknown to the
parties, already ceased to be enforceable. This was pointed out by the Calcutta High Court in
Jagadish Prasad Pannalal v Produce Exchange Corporation Ltd.30

There was a contract for the sale of one wagon of maize starch at the rate of Rs. 77 per cwt,
the control price being Rs. 78. The goods were delivered on January 3 rd and paid for. A few
days earlier, viz. on December 16, a new order was passed by the Government making Rs. 48
as the price and this was to apply to all contracts in which delivery was to be given on or after
January 1st. The buyer brought an action to recover the difference between the revised control
price and the price he paid. The court agreed with him to this extent that the contract had
become void by the change in the control price and, therefore, neither party was compellable
to perform, but that the buyer, having paid up, was not entitled to any refund under Section
65. For this section to apply the advantage must have been received under the 'contract',
whereas, in the present case, the excess price was paid after the contract had already become
void and ceased to be enforceable.31

Discovered to be void

The first part of the section is concerned with an agreement which never amounted to a
contract, it being void ab initio. But the parties discovered this at a later stage. "The word
'discovered' connotes the pre-existence of that which is discovered." This will cover cases of
"initial mistake". Where, for example, money is paid for the sale of goods, which, unknown
to the parties, have already perished at the time, the money is refundable. The principle will
apply whether the agreement is void by reason of law or by reason of fact 32 thus, for example,
where a minor gave a shop under a partnership to the defendant, the agreement being void; it
was held that he could recover back the shop. Similarly, Consideration given on a promissory
note which was not enforceable for inadequacy of stamps was held to be refundable. Money
paid under a contract with a municipality not executed in the manner laid down by the
Municipal Act, was held to be refundable33.

Quantum merit claims — Claims under the well-known English law doctrine of quantum
merit have been allowed by the courts under this section. The Supreme Court observed in
State of Madras v Dunkerley & Co34 that claim for quantum merit is a claim for damages for
breach of contract. The value of the material used or supplied is a factor which furnishes a
basis for assessing the amount of compensation. The claim is not for price of goods sold and
delivered but for damages. That is also the position under Section 65. In another case 35
reasonable compensation was awarded on the implication of a contract. It will not displace an
29
Action for recovery or restitution of ammout paid has to be filled within three years from the date on which
contract ceases to be enforceable Amri Devi v Ridmal AIR 1998
30
ILR (1945)2 Cal 41:AIR 1946 CAL 245
31
Rama Iyer v Jacob (2003)3 KLT(SN)
32
Uttamchand v Mohandas AIR 1946
33
Kishangrah municipalities v Maharaja Kishangrah Mills Ltd AIR 1961
34
AIR 1958 SC 560:1959 SCR 379
35
Alopi Prasad and sons Ltd v Union of India AIR 1960 SC 588(1960) 2 SCR 793

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express stipulation on the point. In a subsequent case, the Supreme Court explained the
requirements of the claim. The original contract must be so discharged by the opposite party
that the plaintiff is entitled to treat himself as free from the obligation of further performance
and he must have elected to do so. The remedy is not available to the party who breaks the
contract even though he might have partly performed it. The remedy is restitutory, it is a
recompense for the value of the work done by the plaintiff in order to restore him to the
position which he would have been in if the contract had never been entered into. In this
respect, it is different from a claim for damages which is a compensatory remedy. The court,
accordingly, did not allow the claim of a contractor for extra payment on the ground that he
had to procure the raw material from a longer distance than that represented in the tender
documents. The material was in fact available within the stated distance, but its removal
required permission of Cantonment Authorities which the contractor could not manage to get.

The restoration of the advantage and the payment of compensation have necessarily to be
mutual. In Govindram Seksaria v Edward Radbore36 the Privy Council pointed out that the
result of Section 65 was that each of the parties became bound to restore to the other any
advantage which the restoring party had received under the contract. As a result of the
contract being void, the State could at the most recover from the contractor the value of the
rough stone excavated from the quarries. But then it would have to make good to the
company the expenditure incurred by it in quarrying operations and extraction of the rough
stone. The contract was for the grant of a quarry. It was found to be void because the parties
were mistaken about the application of income tax laws in the area.

Becomes void

The second type of situation covered by Section 65 is where a valid contract is made in the
beginning, but it subsequently becomes either unlawful or impossible of performance. Any
benefits which have passed under the contract from one party to the other must be restored.
This is subject to the expenses which have already been incurred by the other party in the
performance of the contract.

Conclusion

The law relating to frustration of contract in India is covered statutorily better than that of the
English law as there is no concurrence among judges on the reason behind the frustration of a
given contract, but in India as the provisions are contained in well-defined terms, the change
of conflicting opinion is minimal.

Under the Indian law, the doctrine of frustration is an aspect of law of discharge of contract
by reason of supervening impossibility or legality of contract which comes within the
preview of section 56 of Indian Contract Act 1872. Therefore, the position in effect is that in
Indian law it is not necessary to have any resort to any legal fiction or legal theory for
application of doctrine of frustration. The court in India appear to have understood the real

36
(1946-47)74 IA 295 AIR 1984 PC 56 LR 561

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purport of the provision of the act and then they are applying them correctly to actual factual
situation of contract arising before them for decision37

The decision of English court possesses only a persuasive value but they may be helpful in
showing how the courts have decided cases under circumstances similar to these which have
come up before the Indian courts. In the view of the provision of section 56, the Indian law
on doctrine of frustration seems to lie comparatively on a more sound footing then the
English Law. It is significant to note that fear of misuse of principle of supervening
impossibility by any dishonest party has duly been taken care of in paragraph three of section
56 which obligates the person, who with any innocent person in spite of the fact that such
agreement is otherwise void. This type of structural agreement is not found under English
law. The Indian courts have developed it by process of interpretation. The role played
Supreme Court placed it on a comparatively clear foundation through its remarkable judicial
craftsmanship itself into a clear form and whatever ambiguity there had been in past has been
settled substantially in application of the doctrine.

Bibliography
STATUTES REFERRED

1. The Indian Contract Act, 1872

2. The Law Reform (Frustrated Contracts) Act, 1943

BOOKS

1. Anson’s Law of Contract, 28th edn, (ed J.Beatson), Oxford University Press, New
York, 2002.
2. Cheshire, Fifoot & Furmston’s Law of Contract, 15th edn, (ed M.P. Furmston), Oxford
University Press, New Delhi, 2007
3. Mulla, Indian Contract and Specific Relief Acts, 12th edn, (ed Nilima Bhadbhade),
Vol.1, Butterworths India, New Delhi, 2001
37
Journal of Indian law Institute, Vol 37,No 4(1995) p. 446

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 4. S.S. Ujjannavar, Cases and Materials on Contract, 1983
5. Treitel, The Law of Contract, 12th edn, (ed Edwin Peel), Sweet & Maxwell Ltd.,
London, 2007
6. Avtar Singh, Contract & Specific Relief, 12th edition, Eastern Book Company, 2017

ARTICLES

1. Journal of Indian Law Institute, Vol.37, No.4 (1995)

2. The Cambridge Law Journal, Vol. 24, No. 2 (Nov., 1966)

ONLINE SOURCE

1. https://www.vakilno1.com/bareacts/indiancontractact/indiancontractact.html
2. http://mondaq.com/india/x/407868/Contract+Law/Doctrine+Of+Frustration

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