___________________________________________________________________________

Subject Jurisprudence and legal

theory
TOPIC Savignys Theory of Possession
Research Asst. in Law
Ms. Seema Agarwal

NAME:
ROLL NO.:
COURSE:
Semester

Subir Mondol
55
LLB Three Years, First

DAGAPUR, MATIGARA, SILIGURI

DARJEELING 734010;

W.B.

INDIA

ACKNOWLEDGEMENT

With profound gratitude and sense of indebtedness I place on record my sincerest thanks
to Ms. Seema Agarwal, Assistant Professor in Law, Indian Institute of Legal Studies, for her
invaluable guidance, sound advice and affectionate attitude during the course of my studies.

I have no hesitation in saying that she molded raw clay into whatever I am through her
incessant efforts and keen interest shown throughout my academic pursuit. It is due to her
patient guidance that I have been able to complete the task.

I would also thank the Indian institute of Legal Studies Library for the wealth of
information therein. I also express my regards to the Library staff for cooperating and making
available the books for this project research paper.
Finally, I thank my beloved parents and friends for supporting me morally and guiding
me throughout the project work.

Date: 07.11.2016

Subir Mondol

TABLE OF CONTENTS

__________________________________________________________

Acknowledgement
..2
Research

Methodology...

.4 - 5
A. Aims
and
Objectives..
4
B. Statement
of
Problem.
.4
C. Research
Hypothesis.
. ..4
D. Research
Questions..
..4
E. Methodology of Research..
5
F. Scope
and
Limitations..
..5
G. Review
of
Literature..
.5
H. Mode
of
Citation.
..5
Table

of

Cases
..6
Chapter

I:

Introduction..

.7
Chapter II: Project Topic
A. Sub Categorizatoin
B. Sub Categorizatoin
C. Sub Categorizatoin
Chapter III: project Topic
Chapter IV: Case Study
A. Provisions of Law
B. Facts of the case
C. Issues Involved
D. Judgments referred by the parties
E. Judgments referred by the Court

F. Maxims Used
G. Judgment
H. Own Observation
I. Conclusion
Chapter

V:

Conclusion.

.....23
Bibliography

RESEARCH METHODOLOGY
___________________________________________________________

A. AIMS AND OBJECTIVES

The aims and objectives of this project are to understand the real meaning of Savignys
concepts of Possession, various theories and elements and also what Indian laws say about
possession. One of the aims of the project is to have a comparative study on the topic,
Possession of Law and Possession of Fact, modes of acquisition, Doctrine of Jus tertii, and
finally relation between Possession and Ownership.
B. STATEMENT OF PROBLEM
Despite the laws and Acts, the current systems do not give an equal chance to access and
flourish. Though we have various Laws and Statutes yet essential things are missed out and very
few literates know the proper meaning and nature Possession. As such many of us are still in
dark as to what includes the term Possession and Ownership; which is the bone of contentions.
Common people may never have heard the Doctrine of Jus tertii.
C. RESEARCH HYPOTHESIS
This research work is an attempt to distill lessons from the concept of relation between
Possession and Ownership. It is an attempt to know the concept of various terminologies within
the concept of possession and how they are very much needed in our present day life.
D. RESEARCH QUESTIONS

Based on the statement of problem and research hypothesis aforementioned, the

following research questions have been formulated:
a) Why do people say Possession is a difficult subject ?
b) Are there sufficient understanding on the subject ?
c) How is possession is related with Contract Act ?
d) Who is Savigny and what is his contribution ?
e) Why the burden of proof must lie on the defendant ?

E. METHODOLOGY OF RESEARCH
Methodology implies more than simply the methods the researcher used to collect
data. It is often necessary to include a consideration of the concepts and theories which underlie
the methods. The methodology opted for the study on the topic is Doctrinal. Doctrinal research
in law field indicates arranging, ordering and analysis of the legal structure, legal frame work
and case laws by extensive surveying of legal literature but without any field work.

F. SCOPE AND LIMITATIONS

The research work discusses the key points that the pertinent topic reveals as well as
what is deduced after going through the research work. The topic Possession being very vast like
ocean, the work is limited to the project topic.

G. REVIEW OF LITERATURE
The researcher while writing this project has taken recourse to various primary and
secondary sources. Primary sources would include various laws, books and articles. Secondary
sources would include reports and websites.
H. MODE OF CITATION
A uniform Blue Book Mode of citation has been adopted throughout the project.

TABLE OF CASES

South staffordshire Waterworks Co. Vs Sharman (1896) 2 QB 44.

N.N. Majumdar Vs Sate of West Bengal, AIR 1951 Cal. 140.
Puran Singh Vs Punjab State, AIR 1975, SC 1510.
B. Gangadhar Vs B.R. Rajalingam(1995) 5 SCC 241 ( decided on 12th May 1995).

CHAPTER I : INTRODUCTION

Possession in one word is ownership. It is easily said than understood because it

is more than ownership, and it is more complicated than what it seems to be as we
understand it. The concept of possession raises very many question as to who really
owns it, how one came to possess it, what proof or evidence that one is rightful claimant.
In short it is a relationship between a person and a thing in his possession. However,
sometimes a person may possess one thing but that need not mean that that thing is his.
So we can say that the concept of possession is not only difficult one comprehend but
also difficult to solve. Many Jurists deliberate on the topic, some gave valuable
suggestions, and others left no stone unturned to criticize one another. In the galaxy of
jurist opining on possession, Savigny shine brightly enlightening the complexity of the
problems. He is well appreciated for shedding valuable lights on this topic.
From times immemorial Indian Law had the concept of possession in its system.
In Hindu Law it has an Act by itself: Maintenance and Succession Act 1955. The Smritis
and the Puranas speaks about possession with clarity. It contains references about
acquisition of ownership of property by uninterrupted continuous possession for twenty
years in case of immovable property and ten years in case of moveable property.
The Code of Criminal Procedure 1973, Section 145 (1), (2), (3), (4) in case of
disputes; provides legal protection and support for the person who is the real possessor.
Section 441 of the Indian Penal Code also extends protection against unlawful
interference in the possession, (even way of intimidation, insult, trespass, or intent to
commit an offence). Section 447 gives punishment of three months imprisonment or
fine of Rs. 500 or both.

However, the concept that the proof of the anus lies on the defendant is not very
welcoming. Sometimes might is right may prevail and real owner of the property may lie
in waste.

CHAPTER II : PROJECT TOPIC: THEORY OF POSSESSION

2.1

Project Topic: Theory of Possession

According to Blacks Law Dictionery Possession is The fact of having or
holding property in ones power, the exercise of dominion over property.1
The concept of possession as derived from various studies and discussions has
evolved through various stages. In the beginning it was felt that physical control over a
thing is said to be real possession. After wards it was said that the fact of possession
received recognition and protection under the law only. However, taking the inspirations
from the concept of possession under Roman law, Fiedrich Karl Von Savigny and Ihring
developed their theories of possession on the basis of analysis of the concepts of
possession in fact and possession in law.

2.1.1

Nature of Possession
Possession is one of the most important thing in our works, so it is one of the
most ambiguous. In the whole range of legal theory there is no conception more difficult
than that of possession.2 We know that Possession is the most basic relation between man
and things. Possession of material things is essential to life because the existence of
human life and human society would be rather impossible without the consumption and
use of material things. Therefore many important legal consequences flow from the
acquisition and loss of possession. It is not only proof of ownership but also a mode of
transferring of ownership. It is said to be the nine out o ten points of law meaning

1 Blacks Law Dictionery, Ninth edition, Bryan A. Garner, A Thomson Reuters

business, USA, p. 1282.
2 Ibid., p. 1282.

thereby that it is an evidence of ownership and he who interferes with the possession of
another, must show either title or better possessory right.3
2.1.2

Definition and meaning of Possession

Jurists have defined possession according to their own notions. Some of the
famous definitions are as follows:
that having physical control over a thing constitutes possession. Pollock.
Possession is the physical detention coupled with the intention to hold the thing
detained as ones own. Maine.
There must be the empirical fact of taking possesseion conjoined with the will to have
external object as ones own. Kant.
possession is the de facto exercise of a claim over a thing. Ihering.
The ascertainment of the nature of legal possession is, in fact, indispensible in every
department of law. Holland.

2.1.2.1 Possession as in Fact

The relation between a person and a thing which a person possesses is called
possession in fact or defacto possession. In short, it is a physical control of a person over
a thing. For example, if a person has a parrot in side his cage, he is having possession of
it as long as the parrot is in the cage but as soon as the parrot escapes from the cage or set
free, he would lose possession over it.
2.1.2.2 Possession as in Law
Possession in law is said to be as de jure possession. Actual possession need not
be factual possession testified by legal possession. Therefore, there may be person who
does not have possession in law although he is in actual possession of the object. The law
thus provides certain legal rights on the possessor and punishes those who interferes or
infringes those rights.
Case: Gold rings case: South Staffordshire Waterworks Co. Vs Sharman: In
this case, the plaintiff company owned a pond. The company employed the defendant to
clean the pond. During the cleaning operations, the defendant found gold rings at the
bottom of the pond. The Court held that the company had the first possession of the rings

3 Studies in Jurisprudence and legal theory, Dr. N.V. Paranjape, Central law agency,
Allahabad-2, p. 383.

by virtue of their being the owner of the pond and hence the defendant acquired no title
in the rings and the company was entitled to have the rings.
2.1.2.3 Possession according to Salmond
The possession of a material object is the continuing exercise of a claim to the
exclusive use of it. Possession is a de facto relation between the possessor and the thing
possessed. Possession is a continuing exercise of a right exercised by the owner of it.
He further says: Simple economics dictates that, as a minimum, some measure of
uninterrupted enjoyment is a pre-requisite to mans deriving any benefit or value from
material objects and that such temporary possession must be respected by, and protected
from his neighbours.4
2.1.2.4 Possession under Roman Law
Under Roman law the ceoncept of possession is was used in two different senses.
To be in possession of a thing was different from having legal possession over it. The
former denoted that a person simply has physical control over the things and it was
called corpus possessionis while the latter meant having exclusive control over a thing
which the Romans called as civillis possessionis, i.e., legal possession.
A person was deemed to be in legal possession of ting when not only thing was in
his physical control or he had custody over it, but he also had the power to exclude
others from interference in his possession ( animus ). Thus possession to be legal
required two essential elements: Corpus and Animus.5
2.1.2.5 Possession under English Law
The importance of possession has equally been recognized in English law as well.
The term is commonly used in both civil as well as the criminal law. In civil law, namely,
the law of torts, contract, property, specific etc. many wrongs are defined in terms of
possession. For example, trespass is a wrong relating to possession of land or goods,
conversion is wrong affecting possessory right in goods and is known as trover. In law of
crime, the theft is dishonestly taking away any movable property out of the possession of
any person without that persons consent. The English law recognizes that acquisition or

4 Jurisprudence & legal theory, answers to important questions, Gade Veera Reddy,
Sujata law books Pvt. Ltd., Hyderabad, p.62.
5 Studies in Jurisprudence and legal theory, Dr. N.V. Paranjape, Central law agency,
Allahabad-2, p. 384.

loss of possession results into many important legal consequences. For this reason
Possession has be given protection under law.6

CHAPTER III : SHORT LIFE SKETCH OF KARL VON

SAVIGNY

3.1Life of Savigny
Fiedrich Karl Von Savigny was born on 21 st Feb 1779, in Frankfurt, Germany. He
was a prominent Jurist and legal scholar and known also as the pioneer of influential
Historical School of law through his concept of Volksgeistism. The insufficiency of
natural law school and analytical school provided a fertile land where Fiedrich Savigny
sowed the seeds of historical school. He traced the development of law as a evolutionary
process much before Charles Darwin gave his theory of evolutioi. It is for this reason he
is said to be the Darwinan before Darwin for his contribition to apply the evolutionary
principal to the development of legal system.7
The great German jurist, Friedrick Karl von Savigny, stands as the undisputed
head of the influential historial school of jurisprudence, which he pioneered in the first
half of the 19th century, and as the founder of the study of relations between social and
legal developments. A trail-blazing legal scientist, Savigny made many lasting
contributions to jurisprudence that greatly influenced all the social disciplines as well.
Among these contributions are included the revealing of continuity between present legal
institutions and those of the past, the laying of foundations for legal sociology, and the
articulating of methods for historical research.8

6 Ibid., p. 385.
7 http://www.academia.edu/428817/BASIC_CONCEPT_OF_SAVIGNY_S_VOLKSGEIST,
Friday, 28.10.2016, 8.30 AM.

Fiedrich Karl Von Savigny foundeed his theory of possession on the text of
Roman Jurist Paul and emphasised that possession has two basic elements, namely,
corpus oossessionis and animua domini.9
3.2Possession according to Savigny
According Fiedrich Karl Von Savigny, Possession means an intention coupled
with the physical power to exclude all persons from the use of that material object. The
law gives the protection to the possessor. Possession is a fact. Mere intention is not
sufficient to complete the possession. The physical possession must be coupled with the
intention to possess that material or property. Then only a valid possession is completed.
Corpus possessionis is the second and essential element of possession.10
3.3 Elements of Possessions according to Savigny
Fiedrich Karl Von Savigny founded his theory of possession on the text of Roman
jurist Paul and emphasized that possession has two basic elements- a. Corpus
Possessionis (Physicaly Possessed, and b. Animus Possidendi (Intention to possess). In
other words possession has two elements physical and mental and for valid possession,
these two elements are must. One of them alone cannot form possession and can not
constitute possession.
According to Savigny corpus means, effective physical control of the things, that
is, immediate physical power to exclude any foreign agencys interference by the
possessor. Where as animus means, mental element or conscious intention to hold the
object or thing as owner against all others. According to him there can be no possession
without this mental element.11
8 Legal Philosophers: Savigny: German Lawgiver, Luis Kutner, 55 Marq. L. Rev. 280
(1972).
9 Question and answers on Jurisprudence & Legal theory, Manmohan Singh & S.K.
Husain, central law agency, allahabad-2, p. 210.
10 Jurisprudence & legal theory, answers to important questions, Gade Veera Reddy, Sujata
law books Pvt. Ltd., Hyderabad, p.66.

11 Studies in Jurisprudence and legal theory, Dr. N.V. Paranjape, Central law
agency, Allahabad-2, p. 395.

3.4Corpus possessionis
Corpus implies two things: a. Possessors physical relation to the object (res); b.
The relation of the possessor to the rest of the world. In the first case, the emphasis on
the physical contact of a person with a thing which he possesses so as to give rise to a
reasonable assumption that others will not interfere with it.
3.4.1

The physical power of the possessor

It is a guarantee that the possessor is the user of that thing. It is also an assurance
against the non-interference of others I the right of his possession. (under lock and key)

3.4.2

The personal presence of the possessor

Physical presence is more important than physical strength for resisting
interference. For example, a coin in a childs hand is sufficient to denote his possession
even if he has not physical strength to retain it.

3.4.3

Secrecy
Keeping things hidden is another effective mode of excluding others from
interfering and keeping it secured.

3.4.4

Custom
The modern society believes in cutoms and traditions. If a man ploughs and sows
and reaps the harvest year after year, unless there is something contrary, he may
reasonably be expected to do it again and again and he is in possession of the field.

3.4.5

Respect for the rightful claims

Society always supports rightful claims and prevents others from interfering with
the legal possession of the possessor.

3.5

Animus Possidendi
It is said that mere juxtaposition is not possession. It must indicate some
possibility of physical control accompanied by a will to exercise such control. So the
subjective or mental element in possession is called animus possedendi which means
intention to appropriate and enjoyment of the thing possessed.

Case: N.N. Majumdar Vs Sate of West Bengal, AIR 1951 Cal. 140; In this case
the question of animus came up for the determination before the High Court of Calcutta.
In this case, the police made a search of the accusers house in the hope that the pistol
would be recovered from the house but no such recovery could be made. In the
meantime, the accused had a quick word with his wife who went out and returned within
three or four minutes with a pistol and some cartridges. The police took the plea that as
per Section 27 of the Evidence Act, it should be presumed that the pistol was recovered
from the possession of the accused. The Court however, rejected the contention of the
prosecution and held that the Arms Act being a special enactment, the fact of animus
must be specifically proved and mere existence of corpus without animus is ineffective
to constitute possession.12

3.6Criticism of Savignys theory of possession

According to Fiedrich Karl Von Savigny, protection of possession is a branch of
the protection to person and as any act of violence to person is unlawful, so is the act
which disturbs possession by fraud or force is unlawful. However he was wrong in
assuming that possession cannot be acquired with out corpus and animus and possession
is lost when either of these elements are lost. In actual practice we see that possession
continues even when one of the elements is lost and in some instances even in the
absence of both the elements. Again, Fiedrich Karl Von Savigny has not taken note of the
fact that law does not protect a possession which is acquired unlawfully, although both
the elements may be present in it. Thus a thief of a stolen object is not protected by law.13

12 Studies in Jurisprudence and legal theory, Dr. N.V. Paranjape, Central law agency,
Allahabad-2, p. 395.

13 Questions Answers on Jurisprudence & Legal theory, Manmohan Singh & S.K.
Husain, central law agency, Allahabad-2, p. 215.

CHAPTER IV : POSSESSION UNDER INDIAN LAW

4.1 Possession under Indian Law

According to ancient Indian Law who ever had the title to a land also had the
personal possession of it and was the real possessor of it. Ancient L & L R department
was known as Katyayan, which

says that there are two kinds of possession: a.

possession with title and b. Possession without title. A person not having title to
possession could not claim the right of ownership. Yajnavalkya Smiti also says that if a
person continuously uses anothers property for 20 years he can claim ownership of it.
Gautam and Narada Purans also has similar examples. However, many things changed
with the coming of British Raj. The Indian Law does not accept the distinction between
possession and custody. The concept of possession has great role in determining the
rights and titles relating to property. The right of possession is protected under Section
145 of the Code of Criminal Procedure, 1973.14
14 Studies in Jurisprudence and legal theory, Dr. N.V. Paranjape, Central law
agency, Allahabad-2, p. 407.

Case: Puran Singh Vs Punjab State, AIR 1975, SC 1510: The Supreme Court
in this case held that where a trespasser has continuous, absolute and settled possession
over anothers land, he can not be ejected without recourse to due procedure of law and
he is entitled to retain possession even against the rightful owner unless the latter proves
a better title over the land. The Court reiterated its earlier stand once again regarding
advrse possession in Ram Ratan Vs State of Uttar Pradesh (1977)1 SCR 232.15
Case: B. Gangadhar Vs B.R. Rajalingam(1995) 5 SCC 241 ( decided on 12th
May 1995): In this case the Supreme Court has stated that possession may mean that
possession which is recognized and protected as such by law. Legal possession is
ordinarily associated with de facto possession; but legal possession may exist even
without de facto possession; and de facto possession is not always regarded as possession
in law. A person who although having no de facto possession is deemed to have
possession in law is said to have constructive possession. Explaining the relation
between possession and ownership, the Apex Court further pointed out that ownership is
de jure recognition of a claim to certain property. Possession is the objective realization
of ownership. It is the de facto exercise of a claim to certain property. Possession of a
right is the de facto relation of continuing exercise and enjoyment as opposed to the de
jure relation of ownership. Possession is, in fact, what ownership is in right enforceable
at law to or over the thing.16

15 Ibid., p. 407.
16 Ibid., p. 408

CHAPTER V : CONTRIBUTION OF FIEDRICH KARL VON SAVIGNY

4.1Contribution of Fiedrich Karl Von Savigny

Savigny was a pioneering legal scientist who made lasting
contributions to jurisprudence, particularly in revealing the continuity
of present legal institutions with past ones; in laying the foundations of
legal sociology; and in developing many of the critical methods that
are now used by legal scholars everywhere. In his theory of possession
he says that the essence of corporeal possession is to be found in the
physical power of exclusion. The first is corpus, that is the physical
power to possess a thing for the first time. The second is, having
initially acquired the thing, there must bephysical power to retain it.
Salmond does not agree with Savignys view that possessor must have
physical power to exclude alien interference. The true test according
to him is not the physical power of exclusion, but the improbability of
interference by others.

In Savignys classic words, law is first developed by custom and popular faith,
next by judicial decisionseverywhere, therefore, by internal silently operating powers,
not by the arbitrary will of a law-giver.
Savigny viewed law as a slow, almost imperceptible growth that is formed in
much the same way as a language is. Accordingly, legislation and law codes can, at most,
give mere verbal expression to a body of existing law whose meaning and content can
only be discovered by careful historical investigations. Historical jurisprudence opposed
not only attempts at codification but also those rationalist thinkers who sought to derive
legal theories from general and universal principles without respect to the characteristics
and customs of a particular people. Savigny sought rather to uncover the content of
existing law through historical research.
In 1815, shortly after the appearance of this epochal pamphlet, he founded,
together with K.F. Eichorn and J.F.L. Gschen, the Zeitschrift fr geschichtliche
Rechtswissenschaft (Journal of Historical Jurisprudence), which became the organ of
the new historical school of jurisprudence. In the same year, he began publishing
his Geschichte des rmischen Rechts im Mittelalter (181531; History of Roman
Law in the Middle Ages). This monumental work, in which Savigny used rigorous
critical techniques and consulted a vast body of primary sources, became the foundation
of the modern study of medieval law.
Savigny strove to establish a German science of civil law. His approach to legal
methodology was first put forward in a lecture at Marburg in the academic year 180203
(published in 1951 as Juristische Methodenlehre, nach der Ausarbeitung des Jakob
Grimm; Legal Methodology as Elaborated by Jakob Grimm). He held that legal
science should be both historical and systematic, meaning that it should endeavour to
show the inner coherence of the material handed down in the historical sources
of Roman law.
LATER WORKS: Savigny gave embodiment to his systematic
approach in his eight-volume treatise, System des heutigen rmischen
Rechts (184049; System of Modern Roman Law), a detailed analysis
of Roman law as it evolved in modern Europe. This work also contained
his system of international private law. In 1817 Savigny was made a
member of the Prussian Privy Council. In 1819 he was appointed to the
Berlin Court of Appeal and Cassation for the Rhine Provinces. In 1826
he became a member of the commission for revising the Prussian
code, and in 1842 he gave up his teaching position to accept a
ministerial post as head of the newly founded department for revision
of statutes. The Revolution of 1848 ended his governmental career. In
1850 he published a collection of his monographs, Vermischte
Schriften (Miscellaneous Writings), and in 185153 a two-volume

work, Das Obligationenrecht (The Law of Contracts), a supplement

to his work on modern Roman law.17

17 https://www.britannica.com/biography/Friedrich-Karl-von-Savigny, Friday,
28.10.2016, 3.15 pm

CONCLUSION

BIBLIOGRAPHY

LAST CHAPTER:
a
b
c
d
e
f
g
h
i

CASE STUDY:

Provision of the law

Fact of the case
Issues Involved
Judgment referred by the parties by quoting previous judgments
Judgments referred by the Courts by quoting previous judgment
The real judgment of the case
Maxims used
Your own observations
Conclusion

CONCLUSION AND SUGGESTIONS

BIBLIOGRAPHY

2.2 Elements of Possession

2.3 Theories of Possession
2.3.1 Kants Theory of Possession
2.3.2 Salmonds Theory of Possession
2.3.3 Hollands Theory of Possession
2.3.4 Holes Theory of Possession
2.4 Kinds of Possession
2.4.1 Corporeal and Incorporeal Possession
2.4.2 Mediate and Immediate Possession
2.4.3 Quasi-Possession
2.4.4 Concurrent Possession or Duplicate Possession
2.4.5 Constructive Possession
2.4.6 Adverse Possession
2.5 Modes of Acquisition of Possession
2.5.1 Taking
2.5.2 Delivery
2.5.2.1 Traditio Brevi Manu
2.5.2.2 Constitutum Possessorium
2.5.2.3 Atonement
2.5.3 Operation of Law

Chapter 2
2.1The Continuance of Possession
2.1.1

Possession in Fact and Possession in Law Distinguished

2.1.2

Relation between Possession and Ownership

2.1.3

Possessory Remedies and Proprietary Remedies

2.1.4

Objects of possessory remedies

2.1.4.1 The evils of violent self-help

2.1.4.2 Imperfections of proprietary law
2.1.4.3 Difficulty of the proof of ownership
2.2

Doctrine of Jus tertii

2.3

Possession under the Indian Law

2.4

Relation between possession and ownership restated

I.
II.

TABLE OF CONTENTS
RESEARCH METHODOLOGY
a. Introductory
b. Aims and Objective
c. Statement of the problem:
d. Research Hypothesis:
e. Research Questions: a) Why do people say Possession is a difficult subject ?
b) Are there sufficient understanding on the subject ?
c) How is possession is related with Contract Act ?
d) What is Savigny and what is his contribution ?
e) Why the burden of proof must lie on the defedant ?
f.
g.
h.
i.

III.
IV.

Methodology Used: Doctrinal

Scope and limitation:
Review of Literature:
Mode of Citation: Uniformed mode of citation

TABLE OF CASES:
CHAPTER SCHEME:
a)
b).