INTERPRETATION OF THE TERM ‘CONDONATION OF DELAY’ BY

JUDICIARY

6.1 Civil Justice Administration-II

Submitted by-

Submitted to-

January 2024
MAHARASHTRA NATIONAL LAW UNIVERSITY, NAGPUR
I. ACKNOWLEDGEMNET

“This is to acknowledge that I, Ankita Pandey, 3rd year student of Maharashtra National

Law University, Nagpur would like to express my deepest gratitude to the authorities who

provided their guidance and their knowledge and made it possible to complete the report. I would

like to extend my special gratitude to our faculty, Ms. Sanya Agarwal, whose contribution and

encouragement helped me to conduct this research and complete this project.”

“I would also like to express my thankfulness towards all those who have directly or

indirectly guided me in this research and provided their valuable insights and experiences in

order to make this project a reality.”

1
 II. TABLE OF ABBRIVIATIONS

AIR All India Report

Art. Article

Ed. Edition

v. Versus

s. Section

III. TABLE OF CASES

Cases
Bidhayet prova Devi vs Remandra Nath Chakravarty..................................................................12
Collector (LA) v. Katiji...................................................................................................................9
Kunwar Rajendra Singh v. Rai Rajeshwar Bali and others...........................................................17
Lala Mata Din v. A. Narayan.........................................................................................................17
M/s. Super Metal, Faridabad v. State of Haryana..........................................................................10
Maniben Devraj Shah v. Municipal Corporation of Mumbai........................................................10
Md Iqbal Hossain vs Abdur Rab.....................................................................................................7
Md. Azeem v. Md. Nawaz.............................................................................................................12
N. Balakrishan v. M. Krishnamurthy.............................................................................................10
New Delhi Municipal Council Vs. Pan Singh and Others.............................................................14
New India Insurance Co. Ltd. V. Shanti Misra.............................................................................17
Ramlal, Motilal & Chotelal v. Rewa Coalfields Ltd.:...................................................................16
Shakuntala Devi Jain v. Kuntal Kumari........................................................................................16
Sheo Raj Singh & Ors. v. Union of India & Anr...........................................................................15
Sita Ram v. State of U.P................................................................................................................10
Sk. Md. Taritul Alam and another vs ATM Motiur Islam.............................................................11
State (NCT of Delhi) v. Ahmed Jaan.............................................................................................17
State of M. P. and others vs. Nandlal Jaiswal and others..............................................................14

2
 State of M.P v. Pradeep Kumar.......................................................................................................9
State of Odisha Vs. Purna Chandra Kandi.....................................................................................10
State of Uttaranchal and another Vs. Sri Shiv Charan Singh Bhandari and Others......................14
Union of India and Others Vs. N.Murugesan and Others..............................................................15

IV. TABLE OF STATUTES

Code of Civil Procedure, 1908

Limitation Act. 1963

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V. TABLE OF CONTENTS

I. ACKNOWLEDGEMNET........................................................................................................1

II. TABLE OF ABBRIVIATIONS...............................................................................................2

III. TABLE OF CASES..............................................................................................................2

IV. TABLE OF STATUTES......................................................................................................2

V. TABLE OF CONTENTS.........................................................................................................1

VI. ABSTRACT.........................................................................................................................3

VII. INTRODUCTION................................................................................................................4

VIII. RESEARCH DESIGN..........................................................................................................4

RESEARCH METHODOLOGY......................................................................................................4

RESEARCH PROBLEM.................................................................................................................5

AIM AND OBJECTIVES OF THE RESEARCH..............................................................................5

RESEARCH QUESTIONS.............................................................................................................5

SCOPE AND LIMITATION...........................................................................................................5

RATIONALE OF STUDY...............................................................................................................5

IX. REVIEW OF LITERATURE...............................................................................................5

X. SECTION 5 OF THE LIMITATION ACT..............................................................................6

PERIOD AS PRESCRIBED IN SCHEDULE 1 TO THE ACT..........................................................7

TYPE OF JURISDICTION............................................................................................................8

GENERAL PRINCIPLES UNDER THE LIMITATION ACT..........................................................8

RULE 3A.....................................................................................................................................8

EXCEPTIONS TO CONDONATION OF DELAY............................................................................9

XI. SUFFICIENT CAUSE..........................................................................................................9

1
 ILLNESS OF PARTY...................................................................................................................11

WRONG BUT BONA-FIDE ADVICE OF THE LAWYER...........................................................12

PROCEEDINGS IN WRONG COURT.........................................................................................12

NON-RECEIVING THE COPIES OF JUDGMENT AND DECREE IN TIME...............................12

XII. IMPLICATIONS OF JUDICIAL DISCREATION...........................................................13

XIII. CONDONATION OF DELAY IN WRIT JURISDICTION..............................................13

XIV. LANDMARK JUDGEMENTS..........................................................................................15

XV. CONCLUSION...................................................................................................................18

XVI. BIBLIOGRAPHY...............................................................................................................18

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VI. ABSTRACT

-by Ankita Pandey

The legal maxim “Interest Reipublicae Ut Sit Finis Litium,” which states that a period
of time may be subject to litigation for the general good, is the foundation of the law of
limitations. A general rule of law states that only those who are watchful and diligent
are protected by the law; lazy people are not. The law will not defend those who disre -
gard their rights. The Statute of Limitations establishes the window of time within
which a person who has been wronged may file a lawsuit to seek justice or restitution.
The law of limitations strikes the lawsuit if it is brought after the time limit has been
investigated. The idea is that all legal remedies must be available for a set amount of
time as stipulated by legislation. The opposing party should not go unnoticed by the
court even as it excuses the delay. Remember that he is an unsuccessful party and that
he would have also had to pay hefty legal fees. The primary subject matter of this arti-
cle is the manner in which Section 5 of the Limitation Act, 1908 preserves the rights
and interests of plaintiffs who have neglected to initiate legal actions within the stipu-
lated timeframe. In this paper, an attempt has been made to look at the elements or
reasons that could be demonstrated to be good enough to persuade the judge to over-
look the applicant's inability to appear in court within the allotted time frame. Addi-
tionally, an all-encompassing concept for comprehending the idea that a court's dis-
cretion is required to grant a delay pardon, and that no one can do so automatically,
has been attempted.

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VII. INTRODUCTION

A prescribed time extension under specific circumstances, provided there is good reason, is
known as a “condonation of delay.” The idea of accepting a delay does not extend to suits; it is
mostly favored to applications and appeals. The doctrine’s exclusion of suits is justified by the
fact that it is understood to be an exception to the statute’s general bar of limitation. In judicial
circles, the term "condonation of delay" carries a lot of weight since it captures the complex
ideas that guide the administration of justice. The meaning of this phrase, which is essential to le-
gal procedures, has changed over time as a result of historical circumstances, significant court
decisions, and differing judicial viewpoints.
The legal debate surrounding the “Condonation of Delay” has a historical origin and has under-
gone a dynamic evolution at the hands of the judiciary. The foundation was laid by early inter-
pretations, and significant cases have added to the complex web of its interpretation. After endur-
ing many legal environments, the term today stands at the nexus of modernity and tradition, en-
couraging examination of its current uses, underlying intricacies, and requirement for precise in-
terpretation. The objective of this research paper is to examine the phrase from a historical stand-
point, as well as judicial interpretations and modern applications, in order to highlight its com-
plexity and the difficulties it poses for the legal profession.

VIII. RESEARCH DESIGN

RESEARCH METHODOLOGY

The researcher, for the means of this project, has relied on doctrinal methods of research. All the
sources used and relied upon by this project are secondary in nature. Sources such as books,
articles, journals, blogs and other relevant materials which will contribute the researcher for the
research have been explored. No empirical research, in any manner has been done for the project.

RESEARCH PROBLEM

This study aims to investigate the meaning and application of "condonation of delay" by courts
in judicial processes. This study attempts to shed light on the wider effects of delay condonation

4
on the legal system and its stakeholders by investigating how judicial interpretation affects pro-
cedural justice, legal clarity, and the administration of justice.
AIM AND OBJECTIVES OF THE RESEARCH

Aim: The aim of this research is to comprehensively investigate and analyze the interpretation of
the term “Condonation of Delay” by the judiciary, with a focus on historical perspectives,
contemporary applications, and international comparisons.

Objectives of the research:

1. To understand § 5 of limitation act.

2. To understand the interpretation of Sufficient cause.
3. To understand condonation of delay in writ jurisdiction.
4. To analyze the concept by various latest landmark judgements.
RESEARCH QUESTIONS

5. What is the interpretation of condonation of delay?

6. What is the interpretation of sufficient cause?
7. What is the interpretation of condonation of delay in writ jurisdiction?
8. What is the latest trend?

SCOPE AND LIMITATION

This study's purview includes a thorough analysis of judicial interpretations of the justification
for delays, with a special emphasis on how these interpretations are applied in court. This entails
examining pertinent statutes, case law, and court rulings to comprehend the tenets and elements
that influence judges' judgments when they grant delays.

IX. REVIEW OF LITERATURE

1. C.K. Takwani, (1987) Civil Procedure Code, 9th edition 2021, Eastern Book Company:
The essential rules of civil procedure are covered in this book in a clear and engaging
manner. The study of civil procedure is made more interesting and understandable by the
topic-by-topic treatment of the subject and the references to scholarly literature and judicial
decisions. This book covers all areas and dimensions of law relating to Civil Procedure and

5
 Limitations in India and explains difficult legal topics in a clear and coherent manner. The
author completely reworked and updated the current ninth version of the book.
2. Jatindra Kumar Das, CODE OF CIVIL PROCEDURE, 2014, PHI Learning Pvt. Ltd.: The
book, which was created with the author’s extensive teaching experience at National Law
University and State University, tries to critically assess cases on the Law of Civil Procedure
from the Indian High Court and Apex Court. It also assesses the relationship between case
law as a subject and legislative procedural law.

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X. SECTION 5 OF THE LIMITATION ACT

If there is a valid reason for the delay, the court may excuse it. The objective of this section is to
advance the cause of justice rather than restrict it. Therefore, rather than being interpreted
strictly, these clauses should be constructed loosely. Both the government and the general public
are subject to the same provisions found in § 5. Each case must be considered on its own merits,
considering the relevant facts and circumstances.
The scope of § 5 is limited since the concept of excused delay stated in this section applies only
to appeals, requests for verdicts to be reconsidered or reviewed, requests for leave to appeal, and
any other pertinent applications specified by the most recent legislation. It applies to both the
criminal and civil law areas, but it does not include filing new lawsuits. § 5 does not apply in
cases where special or municipal laws set their own limitations, as specified in sub-§ (2) of § 29
of the Limitation Act, 1908. It is implied that the remaining provisions of the Limitation Act do
not apply unless specifically made relevant by special or local Acts by the wording “the remain-
ing provisions of this Act shall not apply in clause (b) of sub-§ (2) of § 29”.1

PERIOD AS PRESCRIBED IN SCHEDULE 1 TO THE ACT

The period has been prescribed in Schedule 1 to the Act. Generally, it is as follows:

1. 3 years’ time-period for a suit relating to accounts, contracts, suits relating to movable
property, recovery of a lawsuit under a contract, etc.
2. 12 years’ time-period for suits relating to possession of the immovable property, and 30
years’ time-period for suits relating to the mortgaged property.
3. One year for suit relating to torts (3 years for compensation in certain cases). 30 to 90
days in case of appeals under the Civil Procedure Code and Criminal Procedure Code.

1
27 DLR 1975, 418.

7
GENERAL PRINCIPLES UNDER THE LIMITATION ACT

1. Interest republicae ut sit finis lithium: After a protracted hierarchy of appeals, litigation
ends for the benefit of the public. Filing additional appeals may be likened to opening a
floodgate that results in more wrongs than rights.

2. Vigilantibus non dormentibus jura subvenitent: Law helps those who are awake and
alert. The law will not stand by people who disregard their rights. It is important that you
submit the lawsuit within the allotted time frame. Your negligence will not be addressed
by the law.

RULE 3A

An addition to Rule 3A is the Amendment Act of 1976. It states that if an appeal is made after
the deadline has passed, an application needs to be submitted. The applicant must provide a good
reason why the appeal was delayed in being filed. The Privy Council recommended this rule.

The privy council disproved the practice of admitting such appeals subject to a limitation opin-
ion, emphasizing the necessity of establishing a process for resolving the issue of limitation be-
fore appeal acceptance.

The Supreme Court, in the case of State of M.P v. Pradeep Kumar 2, observed two objects of this
rule:

 To notify the party filing an appeal that is past due that it will not be accepted unless it is
accompanied by an application providing adequate cause.
 Notifying the appellant that their appeal may not be heard until the condition precedent of
the pardon of delay has been met.

EXCEPTIONS TO CONDONATION OF DELAY

1. The doctrine is applicable to Criminal Proceedings only.

2. The doctrine does not include “suit” and only covers appeals and applications.

2
(2000) 10 JT 349 (SC)

8
 3. Other than an application under any of the provisions of Order XXI of the Code of Civil
Procedure, 1908. The doctrine covers all appeals and applications.

XI. SUFFICIENT CAUSE

In Collector (LA) v. Katiji3 ruled that § 5 of the Act grants the courts the authority to excuse leg-
islatively-mandated delays. § 5 is meant to assist courts in providing parties with a significant
amount of justice. The Court goes on to say that the definition of “sufficient cause” in § 5 is suf-
ficiently ambiguous to allow judges to meaningfully administer the statute in a way that ad-
vances justice.
To benefit from § 5, the applicant needs to demonstrate that he was prohibited from filing an ap -
plication or appealing within the allotted time frame by a valid reason. Something outside of the
party’s control is considered sufficient cause. It is best to interpret the term “sufficient cause”
broadly. In order to avoid being inactive and careless, the petitioner must persuade the court. It
must be considered that the victorious claimant has acquired a significant entitlement once the
appeal period has elapsed.4
The Apex court in Sita Ram v. State of U.P.5 held that the right of appeal is a matter of sub-
stance, and not of procedure and is paramount. The Court observed,
“Appeal is a remedial right and if the remedy is reduced to a husk by procedural ex-
cess, the right became a casualty. That cannot be.”
The Act's primary goal is to advance substantial justice, which means that technical factors
shouldn't be overemphasized or given undue weight. When evaluating a request for a delay con-
donation, courts have to consider any egregious negligence or lack of bona fides. Maniben De-
vraj Shah v. Municipal Corporation of Mumbai6 is a case in which the court distinguished be-
tween an excessive delay and a few-day delay. The Court determined that while prejudice is con-
sidered in the former case, it is not considered in the later. In M/s. Super Metal, Faridabad v.
State of Haryana7 it was decided that the test conducted in accordance with § 5 of the Act was
exclusively individualistic rather than objective. The Court further concluded that because the

3
(1987) 2 SCC 107
4
Esha Bhattacharjee v. Raghunathpur Nafar Academy (2013) 12 SCC 649.
5
1979 SCR (2)1085.
6
(2012) 5 SCC 157.
7
VATAP No. 27 of 2013 (O&M).

9
term “sufficient cause” is not defined, courts are left with the well-meaning authority to interpret
it in a particular case.
In State of Odisha Vs. Purna Chandra Kandi 8 reiterated what was held in the case of N. Bal-
akrishan v. M. Krishnamurthy9 that:
“Rules of limitation are not meant to destroy the rights of parties. The object of
providing a legal remedy is to repair the damage caused by reason of legal in-
jury. The law of limitation fixes a lifespan for such legal remedy for the redress
of the legal injury so suffered. Time is precious and wasted time would never
revisit. So a lifespan must be fixed for each remedy. Rules of limitation are
meant to see that parties do not resort to dilatory tactics but seek their remedy
promptly. The idea is that every legal remedy must be kept alive for a legisla-
tively fixed period of time.”

It is clear from the legal examples listed above that courts have sufficient power under Section 5
to grant the forgiveness of any legitimate grounds made by parties requesting a delay. Even
though the courts have a great deal of discretion in this area, it is important to remember that
there may be some disparity in the leniency shown to governmental entities.
ILLNESS OF PARTY

A simple claim of illness is insufficient justification. Among the facts to be determined in the
specific case's circumstances is whether the illness’s effect was such that it warranted substantial
cause. When the medical certificate submitted in support of the § 5 of the Limitation Act applica-
tion failed to demonstrate that the petitioner/applicant was in such a serious condition that he was
unable to send someone to inquire about the status of the case or call his attorney at home for ad -
vice. In Sk. Md. Taritul Alam and another vs ATM Motiur Islam10 It was noted that the peti-
tioners' predecessor, who had carried out the lawsuits all the way to the appeals court, demanding
that the defendants be removed from the suit premises, passed away without a will following a
protracted sickness. The High Court Division's experienced judges determined that there was ad-
equate justification for the delay of 285 days in filing the revision.
WRONG BUT BONA-FIDE ADVICE OF THE LAWYER

A lawyer's incorrect advice given with adequate care and caution would be sufficient justifica-
tion for a time exclusion; nevertheless, a lawyer's willful misconduct would not be acceptable. In
8
SLP (Crl) Diary No. 14780 of 2021
9
(1998) 7 SCC 123
10
12 MLR (2007) (HC) 137

10
 the case of Md. Azeem v. Md. Nawaz11, it was decided that the applicant's learned counsel's error
could not have been so serious as to deny his clients the right to § 5 of the Limitation Act, which
allows for the forgiveness of an appeal's filing delay.
PROCEEDINGS IN WRONG COURT

Under § 5, there are several situations in which filing an appeal in the incorrect forum could be
justified as long as the plaintiff and their legal representation used reasonable care and caution
and didn't appear to be irresponsible. It was noted that, although acting in good faith, the peti -
tioner in Bidhayet prova Devi vs Remandra Nath Chakravarty 12 mistakenly believed that their
appeal belonged in the District Judge's court. It was determined that this decision could not
legally prevent the appeal from being registered in the High Court and a request for a delay for -
giveness, even if the District Judge lacked the authority to consider the appeal.

NON-RECEIVING THE COPIES OF JUDGMENT AND DECREE IN TIME

In this case, the appeal's filing delay should be excused under § 5 of the Limitation Act because
the counsel genuinely believed that the time spent obtaining copies and the period between the
date of judgment and the decree’s signing would not count against the statute of limitations. As a
result, the appeal was filed a few days after it should have.

XII. CONDONATION OF DELAY IN WRIT JURISDICTION

The powers to exercise the extraordinary jurisdiction under writ proceedings is conferred to the
High courts under Article 226 of the Constitution of India. A writ petition under article 226 is
filed for the violation of any legal right. The writ is filed once any cause of action arises to the
petitioner. However, no limitation period is prescribed for filing of the writ petition in the consti-
tution or in the Limitation Act of 1963. But absence of any prescribed limitation does not give
blanket right to the petitioners to approach the doorsteps of the court as per their own will and
whims. The aggrieved party is expected to approach the court within a reasonable time to make
sure that they are aware of their rights and duties. One cannot sleep over their rights for years
and then file a writ petition for seeking remedy.

11
PLD 1961 Lahore 137.
12
7 DLR 272

11
In the case of New Delhi Municipal Council Vs. Pan Singh and Others 13 The Hon'ble Apex
Court has stated that, although though Article 226 of the Indian Constitution does not provide a
time limit for filing a writ petition, a writ petition should typically be filed within a reasonable
amount of time. In the aforementioned case, the respondents filed a writ petition seventeen years
later. As previously mentioned, the Hon'ble Apex Court considered the laches and delay as per-
tinent grounds and overturned the High Court's decision to exercise its discretionary authority.

In the case of State of Uttaranchal and another Vs. Sri Shiv Charan Singh Bhandari and Oth-
ers14 Although there is no statute of limitations for filing a writ petition under Article 226 of the
Indian Constitution, the Hon'ble Apex Court has held that writ petitions should normally be filed
within a reasonable amount of time. The Hon'ble Apex Court, as previously mentioned, took
note of the respondents' seventeen-year delay in filing the writ petition and laches as important
circumstances, setting aside the High Court's ruling that had exercised its discretionary authority.

In State of M. P. and others vs. Nandlal Jaiswal and others 15, The Court noted that it is well es-
tablished that the High Court's discretionary power to grant an appropriate writ under Article 226
of the Constitution is limited, and that the High Court typically refrains from assisting those who
are obliging and lethargic or who are sluggish and lazy. Furthermore, it has been noted that the
High Court may decline to intervene and grant relief in the exercise of its writ authority if the pe -
titioner has filed the petition with excessive delay and has not provided a satisfactory explana-
tion. The concept of delay and laches was emphasized, with the statement that using the ex-
traordinary remedy available under the writ jurisdiction too late is likely to cause confusion and
inconvenience.

The issue of delay and laches was considered by the Hon’ble Supreme Court in the case of
Union of India and Others Vs. N.Murugesan and Others 16. It was noted there that a party's in-
ability to perform an act that the law asks of him must obstruct his access to the remedy or relief.
The two crucial elements established by the Honorable Supreme Court are the duration of the

13
(2007) 9 SCC 278
14
(2013) 12 SCC 179
15
AIR 1987 SC 251
16
(2022) 2 SCC 25

12
 delay and the events that transpired in the interim. Waiver of the remedy would occur if it is not
used promptly.

Therefore, it is pertinent to note, that, in absence of limitation for filing a writ petition, the parties
cannot sleep over their rights and then come to court. They are obligated to file the petition
within a reasonable period of time to avoid delay in laches and seek remedy.

XIII. LANDMARK JUDGEMENTS

SHEO RAJ SINGH & ORS. V. UNION OF INDIA & ANR.17: The Supreme Court stressed the
contrast between considering an application for a delay condonation and hearing an appeal of a
High Court judgment that the court decided to give on a discretionary basis. The Court further,
“In the case of the former, whether to condone or not would be the only question whereas in the
latter, whether there has been proper exercise of discretion in favour of grant of the prayer for
condonation would be the question. Law is fairly well-settled that a court of appeal should not
ordinarily interfere with the discretion exercised by the courts below”

RAMLAL, MOTILAL & CHOTELAL V. REWA COALFIELDS LTD.18: In this case, the Court
held that while interpreting § 5 of the Limitation Act, two important considerations need to be
made:
1. The appellant's misrepresentation of the facts in computing the limitation period constitutes
sufficient cause under § 5 to excuse the appellate court's discretion in admitting the appeal;

2. The expiration of the prescribed period of prescription gives rise to a right in favor of the
decree-holder, according to which the decree may be regarded as binding between the
parties. The appeal was accepted.

SHAKUNTALA DEVI JAIN V. KUNTAL KUMARI19: The Court was asked to decide whether § 5
of the Limitation Act should be applied in this case in order to excuse the late filing of the ap -
peal. As established in this case, § 5 of the Limitation Act grants the Court discretion, which
17
CIVIL APPEAL NO. 5867 OF 2015
18
1962 AIR 361
19
AIR 1969 SC 575

13
must be used in accordance with established guidelines for the proper use of judicial power and
discretion. The definition of "sufficient cause" must be interpreted loosely. The three-judge
bench ruled that the application could not be denied or that any delay could not be excused un-
less there was genuine evidence of inaction or carelessness that would deny a party the protec-
tion of § 5. The appeal was allowed and the delay was condoned.

STATE (NCT OF DELHI) V. AHMED JAAN 20: The petitioner had submitted an appeal seeking a
pardon for the delay; nevertheless, the file became confused in the High Court Registry. The
court had to decide whether to permit appeals to be filed late or to be filed again. It was decided
in this case that the sufficiency of a cause—that is, the Court should take a practical and reason -
able approach to explaining each and every day of delay—rather than the duration of the day is
what matters. The delay was condoned and appeal thereby dismissed.

XIV. CONCLUSION

The way that judges perceive a delay's forgiveness is crucial in determining how the legal system
functions. We have looked at the various ramifications that result from how courts understand
and implement this principle through this analysis. The results emphasize how crucial it is for
there to be legal predictability and certainty, procedural justice, judicial efficiency, the creation
of legal precedents, and public trust in the court. It is clear that the fairness and efficiency of the
judicial system can be greatly impacted by how courts interpret the condonation of delay. Incon-
sistencies in interpretation can result in unequal access to justice and undermine public confid-
ence in the legal system, even while judicial discretion is necessary to ensure flexibility and ad -
aptability to specific case conditions.

Ultimately, the legitimacy and efficacy of the legal system depend on a well-balanced strategy
that upholds the values of justice, efficiency, and integrity. Through recognition and resolution of
the consequences arising from judicial interpretations of the justification for a delay, we can
work toward a more just and open legal system that meets the requirements of the community at
large.

20
2008 AIR SCW 5692

14
XV. BIBLIOGRAPHY

I. PRINTED SOURCES
A. BOOKS
 C.K. TAKWANI, CIVIL PROCEDURE WITH LIMITATION ACT, 9TH EDITION 2021
 JATINDRA KUMAR DAS, CODE OF CIVIL PROCEDURE, 2014, PHI LEARNING PVT.
LTD.
 MEDHA KOLHATKAR, M. P. JAIN’S THE CODE OF CIVIL PROCEDURE, 5TH
EDITION. 2019, LEX-ISNEXIS.
 SIR JOHN WOODROFFE AND AMIR ALI’S COMMENTARY ON THE CODE OF CIVIL
PROCEDURE, 8TH EDITION, 2021.
B. REPORTS
 58TH REPORT (1974) ON “STRUCTURE AND JURISDICTION OF THE HIGHER JUDICIARY”
 27TH REPORT (1964) ON “CODE OF CIVIL PROCEDURE, 1908”
II. ELECTRONIC SOURCES
B. WEBSITES
 SCCOnline
 Heinonline
 JSTOR

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