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DAMODARAM SANJIVAYYA NATIONAL LAW UNIVERSITY,

SABBAVARAM, VISAKHAPATNAM, A.P., INDIA.

PROJECT TITLE:
Effect of refusal to accept offer of performance Section 38

NAME OF THE SUBJECT:

Law of Contracts -1

NAME OF THE FACULTY:

Ms. B V S Suneetha mam

NAME OF THE CANDIDATE: SHITANSHU KUMAR SINGH

ROLL- BALLB107

2nd Semester
ACKNOWLEDEMENT

I would like to express my special thanks of gratitude and personal regards to our Contracts
faculty Ms. B V S Suneetha mam for their able guidance and support during the course of this
project on Effect of refusal to accept offer of performance Section 38.
ABSTRACT

“The Indian Contract Act occupies the most important place in the Commercial Law. Without
contract Act, it would have been difficult to carry on trade. It is not only the business community
which is concerned with the Contract Act, but it affects everybody.

The objective of the Contract Act is to ensure that the rights and obligations arising out of a
contract are honoured and that legal remedies are made available to an aggrieved party against
the party failing to honour his part of agreement.” The Indian Contract Act makes it obligatory
that this is done and compels the defaulters to honour their commitments. According to Sir
William Anson. “The objective of law is to maintain order because only in a state of order can a
man feel safe and secure.”

In this project we have dealt with the topic “Effect of refusal to accept offer of performance of
Section 38” and the relevant cases.
TABLE OF CONTENTS

(i) ACKNOWLEDGEMENT………………………………………………….2

(ii) ABSTRACT…………………………………………………………………3

(iii) SYNOPSIS………………………………………………………………….5

(iv) INTRODUCTION………………………………………………………….6

(v) EFFECT OF REFUSAL TO ACCEPT OFFER OF

PERFORMANCE SECTION 38……………………………………………7

(vi) CASE STUDY: Startup v. Macdonald………………………………………

(vii) CONCLUSION……………………………………………………………..

(viii) BIBLIOGRAPHY……………………………………………………………

SYNOPSIS

OBJECTIVE OF THE STUDY

(i) To study about the effect of refusal to accept offer of performance section 38.
(ii) To evaluate the relevant case laws with section 38.
SCOPE OF THE STUDY

The research is restricted to the study of Section 38 of The Indian Contract Law,1872 and the
case laws related to them.

SIGNIFICANCE OF THE STUDY

The research project would be very beneficial in learning about the Section 38 and its provisions
and sub sections.

LITERATURE REVIEW

The research project focuses primarily on primary,electronic and secondary data sources. Data
was gathered from a variety of books, journals, documents, and websites.

PRIMARY SOURCES:

(i) “Contract and Specific Relief” by Avatar Singh.


(ii) “The Indian Contract Act, 1872” 15th edition by Pollock & Mulla.
(iii) Anson’s Law of Contract, 29th edition.

SECONDARY SOURCES:

(i) Indian Kanoon


(ii) EBC reader.

RESEARCH METHODOLOGY

The methodology adopted is doctrinal and does not by any way or means intends to plagiarize
any material from the internet or does not want to violate any individual’s copyright. Data has
been collected from various books, articles, papers and web sources.

RESEARCH QUESTIONS

(i) Whether there are applications of the section 38 in nowadays life?


(ii) Whether there are any effect of refusal to accept offer of performance?
INTRODUCTION

“The Indian Contract Act, 1872 prescribes the law relating to contracts in India and is the key act
regulating Indian contract law. The Act is based on the principles of English Common Law. It is
applicable to all the states of India. It determines the circumstances in which promises made by
the parties to a contract shall be legally binding. Under Section 2(h), the Indian Contract Act
defines a contract as an agreement which is enforceable by law.

Section 38 provides that the promisor is not responsible for non-performance, if his offer of
performance is not accepted by the promisee. The second paragraph provides the conditions of a
valid offer to perform.

The promisor, must offer to perform his obligation under the contract to the promisee. This offer
is called "tender of performance".1 It is then for the promisee to accept the performance. If he
does not accept, "the promisor is not responsible for non-performance, nor does he thereby lose
his rights under the contract". In other words, the tender of performance, if rejected by the other
party, excuses the promisor from further performance and entitles him to sue the promisee for
breach of the contract. Thus, a tender of performance is equivalent to performance. This is the
effect of Section 38.”

1
Hardesh Ores(P) Ltd v Hede & Co, (2007) 5 SCC 614.
EFFECT OF REFUSAL TO ACCEPT OFFER OF PERFORMANCE

“Where a promisor has made an offer of performance to the promisee, and the offer has not been
accepted, the promisor is not responsible for non-performance, nor does he thereby lose his
rights under the contract.

Every such offer must fulfil the following conditions —

(1) it must be unconditional;

(2) it must be made at a proper time and place, and under such circum stances that the person to
whom it is made may have a reasonable opportunity of ascertaining that the person by whom it is
made is able and willing there and then to do the whole of what he is bound by his promise to do;

(3) if the offer is an offer to deliver anything to the promisee, the promisee must have a
reasonable opportunity of seeing that the thing offered is the thing which the promisor is bound
by his promise to deliver. An offer to one of several joint promisees has the same legal
consequences as an offer to all of them.

Illustration :

A contracts to deliver to B at his warehouse, on the first March, 1873, 100 bales of cotton of a
particular quality. In order to make an offer of performance with the effect stated in this section,
A must bring the cotton to B's warehouse, on the appointed day, under such circumstances that B
may have a reasonable opportunity of satisfying himself that the thing offered is cotton of the
quality contracted for, and that there are 100 bales.

Tender: Offer to perform

An "offer to perform" is referred to as "tender" under the English law. The word "tender" is not
used in the section. The first sub-section is chiefly, though not exclusively, appropriate to an
offer of payment; the second and third concern offers of other kinds of performance, such as
delivery of goods.”
The above legal principles were settled in the famous English case Start up vs.Macdonald.2

“The law considers a party who has entered into a contract to deliver goods or pay money to
another as having substantially performed it, if he has tendered the goods or money to the party
to whom the delivery or payment was to be made, provided only that the tender has been made
under such circumstances that the party to whom, it has been made, has had a reasonable
opportunity of examining the goods or the money tendered in order to ascertain that the thing
tendered is really what that it is purported to be”.

Effect of Non-acceptance of Tender

“Where the promisee refuses to accept the performance, the promisor will not be treated as
having performed the obligation. It discharges the promisor from performing that obligation. It
does not, however, discharge the contract. It gives the promisor an option to terminate the
contract and sue for damages. Refusal of a tender of money wrongly does not absolve the party
from its obligation to make payment of the amount and where the obligation to make payment of
the amount is concurrent with the obligation to hand over possession, the claim for recovery of
possession must be accompanied by payment or deposit of the amount. 3 If the creditor will not
take payment when tendered, the debtor must nevertheless continue to be ready and willing to
pay it. The tender may be good defence in an action on the debt, relieve him from payment of
interest after the date of the tender, and entitle him to costs of the proceedings. 4

Tender must be Unconditional

The person making a tender has a right to exclude presumptions against himself by saying: 'I pay
this as the whole that is due, but if he requires the other party to accept it as all that is due, that is
imposing a condition; and when the offer is so made, the creditor may refuse to consider it as a
tender.”

2
Startup v Macdonald, (1843) 5 Man & G 593 at 610.
3
Vidya Vati v Devi Das, (1977) 1 SCC 293 : AIR 1977 SC 397 .
4
Anson's Law of Contract, 30th Edn 2016, p 475; observations in Pyari Mohan Das v Durga Shankar Das, AIR
1958 Ori. 125.
“ A mere specifying of the account on which a payment is offered, though accompanied by such
words as "in settlement" or the like, does not amount to a condition in this sense; for it is no
more than saying that the debtor offers all that he believes to be due.5 More than this, a debtor
may tender, expressly under protest, a greater sum than he admits being due, and thus reserve the
right of taking further proceedings to rest the justice of the claim. Such a protest does not impose
any condition. "The creditor has only to say, "I take the money; protest as much as you please",
and neither party makes any admission'." 6 A tender of the full sum due is not conditional, even if
combined with a demand of something which the creditor is bound by law to perform on being
paid, e.g., requiring a mortgagee to hand over the title-deeds. An incomplete or conditional
tender is not equivalent to payment. Where the payee does not agree to accept payment to a third
party as equivalent to payment to himself, there is no proper tender.

Offer must be of the whole of the promise

Under the Indian law, however, the right of the promisee to reject partial performance is
absolute. With regard to the validity of an offer of performance, it must be not only
unconditional, but entire; i.e., it must be an offer of the whole payment or performance that is
due. Such requirement is not prominent in the section, but the rule applies, because the Act does
not expressly negative the English rule, or because of the words "the whole of what he is bound
by his promise to do" in sub-section (2), or because anoffer to pay or perform only in part is not
really "an offer of performance" of an entire promise at all. A creditor is not bound to accept a
sum smaller than he is entitled to, and therefore, the tender of such a sum does not stop interest
running on it. A comparison with the UNIDROIT Principles would be interesting. The
Principles provide that the promisee may reject offer of performance in part, if the offer is not
coupled with an assurance about the balance of performance.”

Thus, a tender of part with assurance about balance is valid under the Principles. Moreover, the
promisee will be entitled to reject such an offer, only if he has legitimate interest in so doing.
5
Bowen v Owen, [1847] 11 QB 130 at 136
6
Scott v Uxbridge and Rickmansworth Rly Co, (1866) LR 1 CP 596
“This deals with situations, where temporary acceptance will not cause any significant hand to
the obligee. However, if partial performance is accepted, additional expenses entailed thereby by
the promisee must be borne by the promisor so tendering part performance.

Offer of Payment of Part

A debtor must tender the full amount of debt. A creditor is not bound to accept less than what is
due and payable, and therefore by refusing to accept only a portion of the principal amount, he
cannot lose his right to interest on that portion. A tender of part of the entire amount payable is
therefore invalid. An offer to pay an unascertained sum cannot be a valid tender. Tender of
amount after deduction of money order charges is also not valid. 7

A purported tender of less than the debtor admits being due is not a tender at all but an offer of
payment on account, which the creditor may accept or not, and risks nothing by not accepting.
Tender is essentially the offer of a sum which the debtor asserts to be the whole sum due, but
which is less than the creditor claims; for if the parties are agreed on the amount due, a formal
offer is needless and useless. Thus, the creditor refuses money at his peril in case his further
claim turns out unfounded; but if he accepts, the debtor is still only offering what is due, and the
creditor is not bound to make any admission in return. He may take the debtor's offered payment
without prejudice to his claim to a further balance. The debtor is entitled to a receipt for what he
pays, but not to a release. It remains to be seen whether there was a discharge or only a payment
on account. Hence, a tender will be vitiated by the addition of any terms, which amount to
requiring the creditor to accept the sum offered in full satisfaction, or to admit in any other way
that no more is due. If the creditor accepts part payment, he is not precluded from claiming the
residue unless it is the condition of the tender that it is in full discharge.8”

“However, under the Bombay Regulation (5 of 1827), a debtor (including a mortgagor) can
tender even a part of the debt. If the part is tendered as such, and not as in full payment of the
debt, further interest on the amount so tendered ceases under section 14 of the Regulation.

7
Mohanlal Soh v Sabitri Devi Poddar, AIR 1980 Pat. 282 .
8
Beharilal Biswas v Nasimannessa Bibi, AIR 1923 Cal 527 .
In Haji Abdul Rahman v Haji Noor Mohamed,9decided by the Bombay High Court, the
defendant had tendered a sum, which was only a small fraction of the whole sum claimed and
found due. The question in the case was whether interest was due after the date of this offer on
the whole sum or only on the residue. Telang J. thought that the rule in Dixon v Clark, 10 that a
tender of part of an entire debt was bad, applied only to cases when the party making the tender
admitted more to be due than was tendered, and that it had no application where the debtor
tendered the amount as in full payment of the debt. The court decided against the defendant, on
the ground that the tender was ineffectual, as it had not been followed by a payment into court in
the suit, asrequired by an established rule in practice. This opinion of Telang J. was not along
the lines of the true principle involved and the English authorities.

Tender in Instalments

When payment of money or delivery of goods in instalments is provided for by the contract, a
tender of instalments is a good tender. In the absence of any agreement as to repayment of the
loan in instalments, a lender is entitled to decline to receive in instalments, the payment of the
sum due to him, and he can claim that the whole sum due be paid at one and the same time.

A contract made stipulated for delivery to the defendant of 7,500 bags of Madras coast castor
seed to be shipped per "steamers", and then stated that shipment of 2,500 bags was to be made in
December. 1,690 bags arrived on 12 December, and the plaintiff offered their delivery to the
defendant, who refused to take them on the ground that he was not bound to take less than the
whole of the 2,500 bags at one time. The bags were then resold by the plaintiff. The remaining
810 bags of the December shipment arrived on 19 December but were also refused by the
defendant on the same ground, and were also resold by the plaintiff. The plaintiff sued the
defendant for damages for breach of the contract in not accepting the bags. The Court held that
there was a legal and proper tender of the December shipment by the plaintiff according to the
terms of the contract.”

Proper Time and Place


9
Haji Abdul Rahman v Haji Noor Mohamed, (1891) ILR 16 Bom 141.
10
Dixon v Clark, 5 CB 365 : 16 LJ CP 237.
“A tender of a debt before the due date is not a valid tender, and will not prevent interest from
running on the loan. A cheque sent in payment of both monies immediately due as well as of
monies not payable for some time, is not a good tender.

REASONABLE OPPORTUNITY

A tender of goods must be so made that the person to whom the goods are offered has
reasonable time to ascertain that the goods offered are goods of the quality contracted for.

A tender of goods does not mean a delivery or offer of packages containing them, but an
offer of those packages under such circumstances that the person who is to pay for the goods
shall have an opportunity afforded him, before he is called on to part with his money, of
seeing that those presented for his acceptance are really those for which he has bargained.
270”

A tender made at such a late hour of the appointed day that the buyer has no time to inspect
them is not good. In Ruttonsey v Jamnadas, 11 a suit by the plaintiffs for damages for breach
of contract, it was contended for the defendant, that no reasonable opportunity was afforded
to the defendant to examine the goods, as there was no joint survey, and that the time allowed
by the plaintiffs for the examination of the cotton was not sufficient. Holding that the
defendant had reasonable opportunity within the meaning of this section, Latham J. observed:
"Reasonable opportunity of inspection is all that the Act requires. It is the receiving party's
business to verify, not the delivering party's to supply further proof that the goods are
according to contract."

The goods need not be in the delivering party's actual possession; control is enough. The
natural place of inspection is the place of delivery. A tender, which did not disclose the
name of the sender, was not valid. An insured cover, which purported to contain currency
notes amounting to the full sum due was not a legal tender, for the creditor was not bound to
accept the insured cover and take the risk of it not containing the said amount.

Able and Willing


11
Ruttonsey Morarji v Jamnadas Pitamberdas, (1882) 6 Bom 692.
“Sub-section (2) provides that the tender must be made under such circumstances that the
person to whom it is made may have a reasonable opportunity of ascertaining that the person
by whom it is made is able and willing there and then to do the whole of what he is bound by
his promise to do. Being able means having the means, being capable to do what is required.
Being willing means being favourably disposed, favourably inclined, agreeable, having made
a conscious decision to do something.

Mere expression of willingness in the letter to execute a release deed is not proper offer
without having the document ready for delivery. A seller need not be in possession of goods
in order to be ready and willing to deliver. Where a vendor is to notify arrival of goods from
the manufacturers, after which the vendee was to take delivery at the vendor's godown, it was
not necessary for the vendor to prove presence of goods at the godown.

In an action for damages, it is sufficient that the plaintiff was ready up to the time when the
defendant refused to go on with the contract and was ready and willing to do all that was
required to be done by him up to that time. But in a suit for specific performance, the plaintiff
is required to prove readiness to perform his part of the contract from the date of the contract
up to the date of hearing.”

Actual Production of Money

“In an earlier edition of this book, it was stated, citing Mulpuri Veerayya v Saragavarapu
Sivayya,12 as authority, that a tender of money in payment must be made with an actual
production of the money. However, in Ismail Bhai Rahim v Adam Osman, 13 this statement
was doubted and Panckridge J. expressed the opinion that in the Madras case, the contract
may have contained an express obligation to tender. It was held that condition (2) in this
section does not necessarily require the production of money in the case of a debt. On further
consideration, however, it is thought that the statement in the earlier edition may have been
too wide. The tendering of the actual money is of course the best proof of ability and
willingness to pay. It has also been held that a plea of tender before action must be
accompanied by a payment into court after action, otherwise the tender is ineffectual.

12
Mulpuri Veerayya v Saragavarapu Sivayya, (1914) 27 Mad LJ 482: 26 IC 121.
13
Ismail Bhai Rahim v Adam Osman, (1938) 2 Cal 337: 181 IC 539: AIR 1939 Cal 131 .
Where a contract is to be performed by the execution and delivery of a document, a mere
offer by post to execute the document without leaving the document ready to be delivered is
not a valid tender. Where a contract for the purchase and sale of Government paper provides
for the delivery of the paper to the defendant, it is not necessary that the plaintiff should have
taken the Government paper contracted for to the place of business of the defendant and then
and there made an actual tender of it. If the plaintiff was ready and willing to perform his part
of the contract and did his best to inform the defendant by going to his place of business that
he was so, that would be sufficient, in the absence of evidence to the contrary, to constitute
readiness and willingness.”

Manner of Payment

“Payment must be offered in the mode expressly or impliedly authorised by the contract, if so
authorised. Payment by credit card or charge card may be accepted by the creditor.

A creditor is not bound to accept a cheque; but if a cheque is tendered and received, and the
creditor or his agent objects only to the amount, or makes no immediate objection at all, he
cannot afterwards object to the nature of the tender. Downright refusal by the creditor to
accept payment at all precludes any subsequent objection to the form of the tender. The
sufficiency of a tender of money depends on the circumstances of each case. But if a party to
whom tender of money is made, is prepared to accept it or would have been prepared to
accept it, the tender is good, even if it is not strictly according to law, because any objection
to the form of the tender can be waived. It is not open to a party later to object to the form of
the tender. Tender by cheque will be a valid tender, if the person to whom it is tendered is
willing to receive payment by a cheque. But where payment by the Government is of a large
amount, it is reasonable and proper to make it by cheque, and unless the payee went to
collect the cheque personally, the cheque must be sent by post. Therefore, where the
Government waited till the last date of payment and since the payee did not come to collect
the cheque, the dispatch by post of the cheque on that date was held to be according to
ordinary course of business usage, and amounted to tender of payment to the payee on that
day.”
Currency and Rate of Exchange

“The money tendered must be current coin of the country. Where the money obligations are
expressed in a certain currency, the payment must be made in that currency. If the contract
does not indicate the currency for payment, the payment must be made in the currency of the
'place where the payment is to be made. The plaintiff, who brings an action to enforce a
foreign money obligation under a contract; is entitled to claim judgment in foreign currency,
if the proper law of the contract was the law of the foreign country and the money of account
and payment was that of the foreign country.

If the parties have, by agreement, fixed the rate of exchange, the court will apply that rate.
Else, the rule of English law is, that a debt expressed in a foreign currency payable in
England must be converted into sterling with reference to the rate of exchange prevailing on
the day when the debt is paid.

A court in India would have jurisdiction to pass a decree for a sum expressed in foreign
currency; by making the payment of foreign currency subject to permission of the foreign
exchange authorities under the Foreign Exchange Regulation Act, 1973 [now see Foreign
Exchange Management Act, 1999 (42 of 1999)]. Regarding the date for converting foreign
currency into Indian rupees, it was held that a court should pass an order for conversion of
foreign currency on the date of the final judgment.

Tender by whom

Tender may be made by the promisor, or by his agent, unless it was otherwise intended.
Tender for payment of shares by the purchaser's attorney was sufficient proof of readiness
and willingness.”

Tender to Executor of Deceased Promisee


“In Pandurang v Dadabhoy,14 the creditor died, and before taking out probate, the executors
called upon a mortgagor to whom the deceased had lent money on mortgage, to pay the
amount due on the mortgage. The money for repayment was available before the notice
expired, but probate was not obtained until after that date.The debtor offered by letter, to pay
the debt, on a proper release being executed. The Court held that actual tender by production
of money was not necessary, since there was no legally constituted representative to whom it
could be made; and that interest on the mortgage debt should, in the circumstances, stop on
the expiration of the notice, since the executors might, if they had been diligent, have
obtained probate before the date. It was sufficient that the debtor could pay the debt and had
money available for that purpose. But a different view was taken in Ismail Bhai Rahim v
Adam Osman, that a debtor must either tender to a legally constituted representative, or take
the risk of tendering to a person not entitled to receive the debt and of a subsequent suit by
the executor or administrator, or wait until someone obtained probate or letters of
administration and incur liability to pay additional interest in the meanwhile.”

Effect of Repudiation or Prevention by Promisee

“Under the Indian law as well as the English law, prevention by one party amounts to a
fulfillment of the promise by the (other) party prevented in the case of conditional contract or
a contract of reciprocal promises. Where, in an agreement of reconveyance, a party
repudiates the contract before the expiry of the period stipulated for reconveyance, the other
party can sue for specific performance without the formal tender of the purchase price.
Where the contract provided that in case of neglect of the vendor to complete the transaction,
the purchaser was to deposit the sale price in court and the money was not so deposited in the
court but was deposited after the decree, it was held that it would be purposeless making the
deposit, if the vendor had made it clear that he was not going through the sale. Where the
plaintiff agreed to manufacture chairs for a railway company, and after parts had been
delivered, the company gave orders to the plaintiff not to make and send any more, it was
held that the plaintiff was entitled to recover without actually making and tendering the
remainder of the goods.”

14
Pandurang Krishnaji v Dadabhoy Nowraji, (1902) ILR 26 Bom 643.
Offer to one of Joint Promisees

“The last paragraph of the section provides that an offer to one of the several joint promisees
has the same legal consequences as an offer to all of them. If such tender is not accepted by
any of the joint promisees, the promisor is not responsible for non-performance.

It is not necessary for the promisor to tender performance to any other or all the promisees.
If the performance is tendered to one of the joint promisees, and is accepted, does such
accepted performance give a valid discharge to the promisor? The Indian law differs from the
English law in this respect.”

Case Study: Startup v. MacDonald15

Facts:

“Startup (S) contracted with McDonald (M) to supply specified quantity of linseed oil within
the last fourteen days of the month of March. S tendered on the last of the fourteen days at
9’o clock at night. M refused to accept owing to the lateness of hour.

ISSUES:

1) Whether S supplying the goods at such period of time amounted to valid tender?

2) Whether M by denying to take delivery breached the contract?

HELD:

1) The promisee must have a reasonable opportunity of ascertaining that the thing offered by
promisor is thing which latter is bound to deliver. (S.38-2)

15
Startup v Macdonald, (1843) 5 Man & G 593 at 610: 64 RR 810.
Though the time of delivery was unreasonable due to lateness of the usual business hours, yet
there was full and sufficient time for M to weigh, examine and receive into their possession
the delivered oil before midnight (in dissenting opinion, however, C.J. points out there ought
to be reasonable time as well as opportunity. Absence of all workers from the warehouse or
any other reason thereof due to the lateness of the hour could be pleaded as factor negating
the tender for it will not provide reasonable opportunity to examine the product).

In contracts of sale of goods, if parties don’t stipulate the place and time for the performance
of the contract, then according to law, “party who is to receive is bound to attend at a
reasonable place, and wait till a reasonable time, for the purpose of receiving what the other
party is bound to deliver”. If the party bound to deliver doesn’t come at the reasonable place
till the reasonable hour, other party isn’t bound to wait any further and if former comes after
latter has departed, he by his own conduct has rendered tender to be made impossible.

Since in present case, M was present at the warehouse and was in a position to reasonably
ascertain the quality, quantity of the product delivered, hence, there was a valid tender even
when made at unreasonable time for it was made within the time stipulated under the contract
and thus rendered literal possibility of performance within the letter of contract.”

CONCLUSION

The Indian Contract Act is one of the oldest mercantile laws of our country. It came into
effect on the 1st of September 1872 and is applicable to the whole of India with the exception
of Jammu & Kashmir. Containing a total of 266 sections it is the principal law regulating
contracts in India In this project we have dealt with the Section 38 of The Indian Contract
Act ,1872 which stands for the Effect of refusal to accept offer of performance. We dealt
with various sub-sections of the Section 38 with relevant Case Laws.

In this project we also looked forward towards the case study of Startup V. Macdonald. The
facts of the case, the issues raised and the judgement of the honorable court.
BIBLIOGRAPHY

BOOKS:

(i) “Contract and Specific Relief” by Avatar Singh.


(ii) “The Indian Contract Act, 1872” 15th edition by Pollock & Mulla.
(iii) Anson’s Law of Contract, 29th edition.

WEBSITES:

(i) Indian Kanoon.


(ii) EBC reader.

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