DECREE

HIDAYATULLAH NATIONAL LAW UNIVERSITY

CODE OF CIVIL PROCEDURE PROJECT

ON

DEFINE DECREE

SUBMITTED TO

M/s. NEHA SINHA

VIKASH GOEL

SEMESTER IX

ROLL NO. 172

SUBMITTED ON

16TH AUGUST, 2016

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 DECREE
Acknowledgement

I feel highly elated to work on this dynamic topic on DEFINE DECREE. Its ratio is significant in
todays era when there is need to clearly distinguish between decree and judgement in order to facilitate
the execution of the same.

The practical realization of this project has obligated the guidance of many persons. I express my deepest
regard for our faculty M/s. Neha Sinha. Her consistent supervision, constant inspiration and invaluable
guidance and suggestions have been of immense help in carrying out the project work with success.

I extend my heartfelt thanks to my family and friends for their moral support and encouragement.

Vikash Goel

Semester IX TH

Roll no. 172

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Table of Contents

Acknowledgement...........................................................................................2

INTRODUCTION................................................................................................3

ESSENTIAL ELEMENTS OF A DECREE...............................................................5

DECISION WHICH ARE DECREE........................................................................8

DECISION WHICH ARE NOT DECREE................................................................9

Contents of decree..........................................................................................9

CLASSES OF DECREES...................................................................................10

Preliminary decree......................................................................................10

Final decrce.................................................................................................12

Partly Preliminary and Partly Final Decree..................................................13

DEEMED DECREE...........................................................................................15

Meaning of Deemed Decree........................................................................15

Deemed Decrees under Code.....................................................................16

Decree and Judgment Distinction................................................................16

Difference between Order And Decree..........................................................17

CONCLUSION..................................................................................................18

BIBLIOGRAPHY...............................................................................................18

INTRODUCTION

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The adjudications of a court of law may be divided into two clauses (1) decree & (2) order.

The term decree is defined in section 2(2) of the C.P.C. which reads as follows:

Decree means the formal expression of an adjudication which, so far as regards the Court
expressing it, conclusively determines the rights of the parties with regard to all or any of the
matters in controversy in the suit and may be either preliminary or final. It shall be deemed to
include the rejection of a plaint and the determination of any question within section 144, but
shall not include-

a) any adjudication from which an appeal lies as an appeal from an order, or

b) any order of dismissal for default.

Explanation A decree is preliminary when further proceedings have to be taken before the suit
can be completely disposed of. It is final when such adjudication completely disposes of the suit,
it may be partly preliminary and partly final.

Decree is the conclusion reached by the judge after hearing both parties on merits and expressing
the same in writing. Basically decree is the subset in the set of judgment.

The decree forms the last part of the judgment and is extracted from the entire judgment by the
decree clerk who contains the basic details and the result of the case. The date of the decree is the
date of judgment for the purpose of execution though it can be signed anytime later even by a
successor judge though it should be given within 15 days. Even a set-off/ counter claim is in the
same decree.

Judgments by way of an amendment in 1976 must contain the exact decree and words like
decree what is prayed for cannot be used. Thus every judgment contains the decree, amongst
other things and the decree is usually the last portion of the judgment and the decree
independently is without reasoning.

There is no need of a statement in a decree though it is necessary in a judgment. Likewise, it is

not necessary that there should be a formal expression of the order in the judgment, though it is

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desirable to do so. A judgment is a stage prior to the passing of a decree or an order, and after the
pronouncement of the judgment, way for the decree has to be left wide open.

Decree has to be in line with the judgment and it should present the correct interpretation of the
judgment. But in case, scenario arises where there appears to be a conflict between the judgment
and the decree, then the decree must be reasonably construed and if on such construction both of
them able to remain together, then adhere to that decree. But if it gets difficult for the decree to
stay together with the judgment, then it must be amended under section 151 of the C.P.C. and if
there is any clerical mistakes in the decree, then section 152 of the C.P.C. will take out the decree
safe from the clutch of being declared nullity.

Scope

It matters not that the judgment is headed an order, for, if it in fact fulfils the conditions of the
definition under s 2(2), it is a decree and an appeal lies.

In the definition, some orders which otherwise do not constitute decree are also included and
certain orders which constitute decree have been excluded from it. Merely because there exists
some order captioned as a decree drawn up even in the form of decree, it would not make such
an order decree unless the court satisfied the requirement of s 2(2) of the Code of Civil
Procedure. A decree or order becomes enforceable from its date, but in appropriate cases, the
court passing the decree may prescribe the time wherefrom the decree becomes enforceable on a
future date. In a case where the language of the decree is capable of two interpretations, one of
which assists the decree-holder to obtain the fruits of the decree and the other prevents him from
taking the benefits of the decree, the interpretation which assists the decree- holder should be
accepted. The policy of law is to give a fair and liberal, and not a technical construction, enabling
the decree-holder to reap the fruits of his decree.

OBJECTIVE

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The objective of the project is to,

1. Study the definition and concept of decree

2. Study the various essentials of a decree

3. Study the various classes of decree

4. Study the distinction between order, decree and judgement.

RESEARCH METHODOLOGY

The method of research adopted is analytical in nature. I have referred sources on the internet as
well as a few books on Code of Civil Procedure available in the university library besides adding
my personal views and knowledge of the topic. Books and other references as guided by the
faculty of Code of Civil Procedure have been primarily helpful in giving this project a firm
structure. Websites, dictionaries and articles have also been referred.

ESSENTIAL ELEMENTS OF A DECREE

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Their 5 main element of decree if they are not present then decree is not their. Following are the
element of the decree.

1. There must be an adjudication.

2. Such adjudication must have been done in suit.

3. It must have determined the rights of the parties with regards to all or any of the matters in
controversy in the suit.

4. Such determination must be of a conclusive nature, and

5. There must be a formal expression of such adjudication.

Adjudication
For a decision of a court to be a decree, there must be an adjudication, i.e. a judicial
determination of the matter in dispute. If there is no judicial determination of any matter in
dispute, it is not a decree. Thus, a decision on a matter of an administrative nature, or an order
dismissing a suit for default of appearance of parties or dismissing an appeal for want of
prosecution cannot be termed as a decree inasmuch as it dose not judicially deal with the matter
in dispute. Further, such judicial decision determination be by a court. Thus, an order passed by
an officer who is not a court is not a decree.1

Suit
The expression suit is not defined in the code. But in Hansraj Gupta v. Official Liquidators of
The Dehra Dun-Missoorie Electric Tramway Co. Ltd., Their Lordship of the Privy Council Have
defined the term in the following words, The word 'suit' ordinary means and apart from some
context must be taken to mean, a civil proceeding instituted by the presentation of a plaint.
Thus, every suit is instituted by the presentation of a plaint. It means that when there is no civil
suit, there is no decree. Thus, rejection of an application for leave to sue in forma pauperis is not
a decree, as there is no plaint till the application is granted.

1 Deep Chand v. Land acquisition officer, (1994) 4 SCC 99

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It may, however be noted that under certain enactment specific provisions have been made to
treat applications as suits, e.g. proceedings under the Indian Succession Act, the Hindu Marriage
Act, the Land Acquisition Act, etc. They are statutory suits and the decision given thereunder are,
therefore, decrees. Therefore a proceeding which dose not commence with a plaint and which is
not treated as a suit under any act, cannot be said to be suit under the code also and the decision
given therein cannot be said to be a decree under section 2(2) of the code. Thus, a decision of a
tribunal, even though described as a decree under the act, is a decree passed by a tribunal and not
by a court covered by section2(2).2

Rights of parties in controversy

The adjudication must have determined the right of the parties with regards to all or any of the
matters in controversy in the suit. The word right means substantive rights of the parties and
not merely procedural rights. Thus, rights of the parties inter se relating to status, limitation,
jurisdiction, frame of suit, account, etc. are rights of the parties under this section. The rights in
matters of procedure are not included in it. Thus, an order for dismissal of a suit for default of
appearance, or an order dismissing an application for execution for non-prosecution, or an order
refusing leave to sue in forma pauperis, or a mere right to sue are not decrees as they do not
determine the rights of parties.

The term parties means parties of the suit, i.e. the plaintiff and the defendant. 3Thus, an order
on an application by a third party, who is a stranger to the suit, is not a decree. In inter-pleader
suits, the contesting defendants will be deemed to be parties to the suit.

The expression matters in controversy refers to the subject-matter of the suit with reference to
which some relief is sought. At the same time , however, it should not be understood as relating
solely to the merits of the case. It would cover any question relating character and status of a
party suing, to the jurisdiction of the court, to the maintainability of a suit and to other
preliminary matters which necessitate an adjudication before a suit is enquired into. Interlocutory
orders on matters of procedure which do not decide the substantive rights of the parties are not

2 Diwan bros. v. Central Bank of India, (1976) 3 SCC 800

3 AIR 1976 Guj. 152

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decrees. Similarly, the proceedings preliminary to the institution of a suit also will not be
included in the definition.

Conclusive determination

Such determination must be of a conclusive nature. In other words, the determination must be
final and conclusive as regards the court which passes it. 4Thus, an interlocutory order which
dose not decide the rights of the parties finally is not a decree, e.g. an order refusing an
adjournment or an order striking out decree of a tenant under the relevant Rent Act, or an order
passed by the appellate court deciding same issue and remitting other issues to the trial court for
determination under order 41 rule 23 of the code are not decrees because they do not decide
rights of parties conclusively.

On the other hand an order may determine conclusive the rights of the parties although it may
not dispose of the suit. Thus, an order dismissing the appeal summarily under order 41 of the
code or holding it to be not maintainable or a decision dismissing a suit for want of evidence or
proof are decrees in as much as they decide conclusively the rights of the parties to the suit.
The crucial point which require to be decided in such a case is whether the decision is final and
conclusive in essence and substance. If it is, it is a decree, if not, it is not a decree.

Formal expression

There must be a formal expression of such adjudication. All the requirement of form must be
complied with. The formal expression must be deliberated and due in the manner provided by
law. The decree follows the judgement and must be drawn up separately.5 Thus, if the decree not
formally drawn up in form of judgement, no appeal lies from that judgement. But the decree
need not be in a particular form. Thus, a mis description of a decision as order which amounts to
a decree dose not make it less than a decree.

4 Narayan Chandra v. Pratirodh Sahini, AIR 1991 Cal 53

5 AIR 1969 SC 575

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DECISION WHICH ARE DECREE.

1. Order of abatement of suit.

2. Dismissal of appeal as time barred.

3. Dismissal of suit or appeal for want of evidence or proof.

4. Rejection of plaint for non-payment of court fees.

5. Granting or refusing to grant costs or installment.

6. Modification of scheme under section 92 of the code.

7. Order holding appeal not maintainable.

8. Order holding that the right to sue does not survive.

9. Order holding that there is no cause of action.

10. Order refusing one of several reliefs.

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DECISION WHICH ARE NOT DECREE.
1. Dismissal of appeal for default.

2. Appointment of commissioner to take account.

3. Order of remand.

4. Order granting or refusing interim relief.

5. Return of plaint for presentation to proper court.

6. Dismissal of suit under order 23 rule 1.

7. Rejection of application for condonation of delay.

8. Order holding an application to be maintainable.

9. Order refusing to set a side sale.

10. Order directing assessment of mesne profit.

Contents of decree
The decree shall agree with the judgement, it shall contain the number of the suit te name and
description of the parties, there registered address, and particulars of the claim and shall specify
clearly the relief granted or other determination of the suit.

The decree shall also state that the amount of cost incurred in the suit, and by whom or out of
what property and in what proposition such cost are to be paid.

The court may direct that the cost payable to one party by the other shall be set of against any
sum which is admitted or found to be due from the former to the latter.

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CLASSES OF DECREES

The code recognizes the following classes of decrees:

i) Preliminary decree
ii) Final decree;
iii) Partly preliminary and partly final.

Preliminary decree
An adjudication which finally decides the rights of parties, hut does not completely dispose of
the suit is a preliminary' decree. Thus, preliminary decree is one which declares rights and
liabilities of parties leaving actual result to be worked out in further proceedings. 60 A preliminary
decree is only a stage in working out the rights of the parties which are finally adjudicated by the
final decree. Whereas final decree completely disposes of the rights of the parties in respect of all
or any of the matters in controversy. The question whether a decision amounts to a preliminary
decree or not is one of great significance in view of the provisions of Section 97 of the Code
which provides that : Where any party aggrieved by a preliminary decree ... does not appeal
from such decree, he shall be precluded from disputing its correctness in any appeal which may
be preferred from the final decree." Since the passing of a preliminary decree is only a stage
prior to the passing of a final decree, if an appeal preferred against a preliminary decree
succeeds, the final decree automatically falls to the ground for there is no preliminary decree
thereafter to support it. It is not necessary in such a case for the defendant to go to the court
passing the final decree and ask it to set aside the final decree. Explaining the nature and scope
of preliminary decree in Anubai v. Vithoba Shripali Savant. the Bombay High Court observed:

A preliminary decree is passed in those cases in which the Court has first to adjudicate upon the
rights of the parties and has then to stay its hands for the time being, until it is in a position to
pass a final decree in the suit. In other words, a preliminary decree is only a stage in working out
the rights of the parties which are to be finally adjudicated by a final decree. The preliminary

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decree adjudicates the rights of the parlies with regard to ail or any of the matters in controversy
in the suit, but does not completely dispose of the suit, such decree is called a preliminary decree.

The Code provides for passing of preliminary decrees in the suit for partition and separate
possession under Rule 18, Order 20. A partition suit in which a preliminary decree has been
passed is still a pending suit and the rights of parties who are added after the preliminary decree
have to he adjusted at the time of final decree. The preliminary decree is only a stage prior to the
passing of a final decree. As regards the partition suit, in Phoolchanil v. Gopal Lai.6 the Apex
Court observed that there is nothing in Code which prohibits passing of more than one
preliminary decree, if circumstances justify the same and it may be necessary to do so. These
observations are made by the Apex Court specifically dealing with the partition suit.

The Code provides for passing of preliminary decrees in the following suits:

Suits Order Rule/Rules

Suits relating to possession and mesne profits 20 12
Suits relating to administration 20 13
Suits relating to pre-emption 20 14
Suits relating to dissolution of partnership 20 15
Suits relating to accounts between principal and agent 20 16
Suits relating to partition and separate possession 20 18
Suits relating to foreclosure of mortgage 34 2-3
Suits relating to sale of mortgaged property 34 4-5
Suits relating to redemption of mortgage 34 7-8

The above list is, however, not exhaustive and the court may pass a preliminary decree in cases
not expressly provided in the Code.7 A preliminary decree can be taken in appeal only within the
period of limitation. If the limitation period is over, then the party cannot dispute the correctness
of the preliminary decree in the appeal from the final degree.

6 AIR 1967 SC 1470

7 AIR 1953 TC 220

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There is a conflict of opinion as to whether there can be more than one preliminary decree in the
same suit. Some High Courts have taken the view that there can be only one preliminary decree
in a suit, while other High Courts have held that there can be more than one preliminary decree

Final decrce
A decree may be said to be final in two ways:

i) when within the prescribed period no appeal is filed against the decree or the matter
has been decided by the decree of the highest court; and
ii) when the decree, so far as regards the court passing it, completely disposes of the
suit.

A final decree is one which completely disposes of a suit and finally settles all questions in
controversy between parties and nothing further remains to be decided thereafter. Thus, in a suit
for recovery of money, if the amount found due to the decree-holder is declared and the manner
in which the amount is to be paid has also been laid down, the decree is a final decree. Similarly,
a decree passed for a sum representing past mesne profits and future mesne profits at a particular
rate, without directing any further enquiry, is a final decree. Thus, where a decree passed by a
special court did not contemplate any further proceedings, the decree, even though described as a
preliminary decree, in substance was a final decree.

Ordinarily, there will be one preliminary decree and one final decree in one suit.34

Table: Distinction between Preliminary and Final Decree

Preliminary Decree Final Decree

1. Preliminary decree is granted even before
the final disposal of the suit.
2. Preliminary decree is superior.
3. If the preliminary decree is set aside in
appeal, then the final decree is also auto
matically set aside.
4. Appeal against preliminary decree must
be filed within the limitation period.
5. Preliminary decree ascertains what things
are to be done.
1. Pinal decree is granted after the final disposal of
the suit.
2. The final decree is subordinate to preliminary
decree.
3. If the final dccrcc is set aside in appeal, then the
preliminary decree is also automatically set aside.
4. If the final decree lapses after limitation period, it
cannot be disputed in appeal.
5. Pinal decree states the results achieved by the
means of the preliminary decree.

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6. Preliminary decree may be generally 6. Pinal decree is generally present with or without
present or absent. preliminary decree.

Partly Preliminary and Partly Final Decree

The Code of Civil Procedure itself contemplates the possibility of a decree partly preliminary
and partly final. According to the Explanation to Section 2(2) of the Code, a decree is
preliminarywhen further proceedings have to he taken before the suit can be completely
disposed of and decree is finalwhen the adjudication completely disposes of the suit and that a
decree may be partly preliminary and partly final. Explanation to Section 2(2) of the Code reads
thus:

A decree is preliminary when further proceedings have to be taken before the suit can be
completely disposed of. It is final when such adjudication completely disposes of the suit. It may
be partly preliminary and partly final.

This Explanation did not appear in the definition of decree in the Code of 1882. Therefore, the
crucial words it may be partly preliminary and partly final needs explanation. In Ramabai
Govind v. Anani DajiT the Bombay High Court held that a decree can be partly final and partly
preliminary only when it deals with different matters in different ways, and that a decree or the
part of a decree in the form provided for by Rule 18(2), Order 20 must be either final or
preliminary. In Han Mohan Thakur v. Mahendra NarainChand , the Patna

High Court held that the mere Tact that a decree is labelled as preliminary is in no way
conclusive. The law visualises a synthesis in this context and envisages a hybrid. It, therefore,
follows that even though in a partition suit where the decree may be named as preliminary it may
nevertheless have the attributes of finality as well in certain aspects. It is true that it cannot be
executed forthwith as such but so far as the adjudicatory and determinatory process of the rights
and interest of the parties is concerned, it might well be final.

In Sri Bhasker Saikia v. Suit. Talari Devi, the Gauhati High Court observed that from a bare
reading of the definition of decree, it becomes clear that when there is formal expression of an
adjudication by a Civil Court conclusively determining the right or rights of the parties with
regard to all matters in controversy in the suit and nothing remains for adjudication, becomes a

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final decree. Inasmuch as a preliminary decree, as the Explanation to Section 2(2) of the Code
shows, is a decree, when further proceedings have to be taken before suit can be completely
disposed of; whereas, a final decree is one, where adjudication has been made and the suit has
been completely disposed of. In a given case, however, a decree may be partly preliminary and
partly final.

Now question arises if a decree is partly preliminary and partly final whether that part of the
decree which is final is executable? In Bhargavi Pillai v. Vijayamma, the Kerala High Court held
that in a case where a decree is partly preliminary and partly final it cannot he said that that part
of the decree which in the beginning itself was final would cease to be an executable decree on
the passing of the final decree resulting in the erasure of that part of the decree which was, to
start with, a preliminary decree.

Recognising the fact that a decree may be either preliminary or final and may be partly
preliminary and partly final the Madras High Court in Sivalinga Pathar v. Narayani Animal, held
that in the present case, the decree does not refer to either Schedule B or Schedule C. It covers all
items in Schedule A except the third item which being in the hands of an alienee, was not dealt
with. Out of the remaining nine items, six were allotted to the plaintiff and three to the first
defendant. One of the three items given to the first defendant consisted of the family house being
item I and the decree provided that the second defendant's widow was entitled to reside in the
portion thereof which was marked out by the commissioner. Any reallotment that could possibly
be made thereafter at the final decree stage could only be with reference to those nine items.
There could be no further variation of this decree either by consent of parties or by order of
Court, so far as the conceding to the plaintiff of a half share in the divisible properties went.
Therefore the argument that the decree in question does not amount to he a decree because of the
existence of this reservation therein has no force. It will therefore be right to call this a decree
partly preliminary and partly final because so far as it affects the particular items in question, it is
in the nature of a final decree subject only to its being varied if necessary by way of re-allotment
of the items by consent of the parties.

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DEEMED DECREE
Meaning of Deemed Decree
An adjudication not fulfilling the requisites of Section 2(2) of the Code cannot be said to be
decree. By a legal fiction, however, certain order and determinations are deemed to be
decree within the meaning of Section 2(2). The term deemed is used in several statues in
different senses. Sometimes it means generally regarded; at other times, it signifies taken
prima facie to be. It may also mean, taken conclusively to be. Whenever the word deemed
is used in a statute in relation to a person or thing, it implies that the legislature, after due
consideration, exercised its judgment in conferring that status or attribute to a person or thing. In
M/s. Arneya Presence Marketing v. Mangalore City Corporation, the Karnataka High Court
observed:

The term deemed* is used in the statute in various senses. Sometimes it means generally
regarded, taken prima fade to be, and taken conclusively to he. When used in a statute it means
some matter or thing has happened, the way in which it has to be attached. When a statute
enacts that something should be deemed to be done, which in fact and truth was not done, the
Court is required to ascertain for what purpose and between what persons statutory fiction was
intended to be resorted to. In the modern statute, this expression is used to introduce artificial
conceptionswhich arc intended to go beyond legal principles and to give an artificial
construction to a word or a phrase. The deeming provision is generally made to include what is
obvious or what is uncertain or to impose for the purpose of a statute an artificial construction
of a word or phrase that would not otherwise prevail.

A deeming provision may also be made to include what is obvious or uncertain or to impose an
artificial extension of a word or phrase that would not otherwise be possible. Thus, the meaning
to be attached to the word deemed" must depend upon the context in what it is used. 85 A
question may, therefore, arises as to the effect of such legal fiction. Now a deeming provision
creates a legal fiction. The effect of such legal fiction is that a position which otherwise would

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not be there, is deemed to be present under certain circumstances. An effect must, therefore, be
given to such legal fiction.

Deemed Decrees under Code

Section 2(2) of the Code defines decree. But it also states that the rejection of a plaint" as well
as the determination of a question underSection 144 would he deemed to be a "decree.
Likewise, certain orders passed or made in execution proceedings are deemed to be decrees
under the Code. Thus, under the Code a decree is deemed to include:

1. The rejection of a plaint;

2. The determination of any question concerning an application for restitution; and

3. the adjudication of claims to or objection to attachment of property.89

Decree and Judgment Distinction

1. S 2(9) defines Judgment as the statement given by the judge on the grounds of a decree
or order,8 whereas it is not necessary for the judge to give a statement in a decree though
it is necessary in a judgment.

2. It is not necessary that there should be a formal expression of the order in the judgment,
though it is desirable to do so where as in decree there is formal expression of court is
necessary.9

3. A judgment contemplates a stage prior to the passing of a decree or an order, and, after
the pronouncement of the judgment, a decree shall follow.10

8 CPC bare act

9 Civil procedure code by c.k takwani

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Difference between Order And Decree

In spite of the common elements, there are fundamental distinctions between the two
expressions:

1. A decree can only be passed in a suit which commenced by presentment of a plaint. An

order may originate from a suit by presentment of a plaint or may arise from a proceeding
commenced by a petition or an application.

2. A decree is an adjudication conclusively determining the rights of the parties with regard
to all of the matters in controversy; on the other hand, may or may not finally determine
such rights.

3. A decree may be preliminary or final, or partly preliminary and partly final, but there
cannot be preliminary order.

4. Except in certain suits, where two decrees, one preliminary and the other final are passed,
in every suit there can be only one decree; but in the case of a suit or proceeding, a
number of orders may be passed.

5. Every decree is appealable, unless otherwise expressly provided,11 but every order is not
appealable. Only those orders are appealable as specified in the code.12

10 S. 33

11 S.96

12 S.104, Or.43 R.1.

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6. A Second Appeal lies to the High Court on certain grounds from the decree passed in the
first Appeal.13 Thus, there may be two appeals; while no second Appeal lies in case of
appealable orders.14

CONCLUSION

As for decree is concerned, it is the final stage of the stage of suit. In the conclusion I can say
that decision given by the judge is called judgment which contains the grounds of the decree and
order. Decree and order are analogous to each other. They are defined under section 2(2, 9, and
14). The importance of decree lies in fact that they are appealable and conclusively determine the
rights of the parties. There is difference between order, decree and Judgment.

I have also taken one decree for the reference in this project. This make project very clear about
the topic and what decree and clears all the doubts from the mind of general people.

But in practical day to day life it this procedure not be fulfilled but still judgment is valid and this
is the lacuna of this Act which required to be amended and need to some change.

BIBLIOGRAPHY
BOOKS

1) Tripathi, T.P, Code of Civil Procedure, 2nd edition 2008, Allahabad Law Agency

13 S.100

14 S.104(2)

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2) Thakkar,C.K, Code of Civil Procedure, 5th edition, 2003, Eastern Book Company,
Lucknow

3) Singh Avtar, the Transfer of Property Act, Universal Law Publishing Co.

4) Sinha R.K., the Transfer of Property Act, Central Law Agency.

WEBSITES

1) www.manupatra.com

2) www.vakilno1.com

3) www.ebc-india.com

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