University Institute Of

Legal Studies
Panjab University

CPC
AMENDMENT OF PLEADINGS

Submitted to:

Submitted by:

Dr. Karan Jawanda,

Harshit Anand

(CPC)

136/12, 7th sem.,

UILS,PU.

B.com.llb.(Hons)

Acknowledgement
I wish to convey my greatest appreciation to Dr. KARAN JAWANDA, a
professional professor and great mentor, who challenged and organized my
thoughts and helped convert them to the written words.
I would also like to thank UNIVERSITY INSTITUTE OF LEGAL STUDIES,
PANJAB

UNIVERSITY,

CHANDIGARH,

for

their

initial

faith

and

encouragement that I submit my project report.

I am indebted to my friends and other family members for providing
kindness and help in making this project.

TABLE OF CONTENTS
S.NO

TOPIC

Page No

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2.
3.
4.
5.
6.
7.
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11.
12.
13.
14.
15.

Introduction
What are pleadings?
Interpretation
Object of RULE
Nature and Scope
Leave to amend when granted
Introducing new and different case
Interpreting at any stage
Pre trial and Post trial amendment
Doctrine of Relation Back
Amendment to written statement
Amendment based on subsequent events
Effect of 2002 Amendment
Conclusion
Bibliography

4
5
5-6
6-7
7
7-8
8-10
10-11
11
11-12
12
13
13-14
15
16

INTRODUCTION
The Code of Civil Procedure, 1908 prescribes the provisions through which
the amendments to pleadings can be introduced during the trial process.
Since the bygone era, the belief of almost all the legal systems was that the
courts must have unrestricted and unguided power to amend the pleadings
so as to further the cause of justice without causing an iota of injustice to the
adversary party. Rule 17 of Order VI provides for the powers to the courts in
India to allow the amendments. Adding to this, the Privy Council, the
Supreme Court and other Courts in India have been implementing this
3

practice since the ages. In 1990s, a lot of concerns were raised as to the
extent of usage of this facility in almost all the cases litigated till then.
Various reports found that no stone has been unturned not to utilize this
provision and hence there is a need for a re-look1.
By the Code of Civil Procedure (Amendment) Act, 1999, this provision
relating to amendment of pleadings was deleted. Justice Malimath
Committee recommended that the rule 17 of this order be deleted to avoid
delay and to ensure speedy disposal of cases2. This amendment act received
the assent of the President but was not brought into force. Due to a lot of
uproar in the Country and opposition from lawyers, the government
reconsidered the question and revived the rule by the next amendment act
in 2002 with a proviso. However, it was reintroduced by the Code of Civil
Procedure (Amendment) Act, 2002, but with a proviso and was brought into
effect from July 1, 2002.
In this backdrop, it0 is important for us to understand the discourse by which
this law on amendment of pleadings has been developing either by way of
the legislative enactments or by way of judicial activism.

What are Pleadings?

Order VI deals with pleadings in general. Rule 1 of that Order defines
pleadings as a plaint or written statement. Plaint is used to notify the
opposite party of the case that is filed against him or her. Framing of
pleadings is the most fundamental and must be dealt with a lot of caution.
The reason is that, once the pleadings are framed, no one has the power to
amend them expect for the judge on his discretion. In the absence of the
pleadings, if any evidence is produced by the parties, that cannot be
considered. It is a settled law that no party must be allowed to venture
1 http://lawcommissionofindia.nic.in/reports/report222.pdf.
2http://www.prsindia.org/uploads/media/Division%20High%20Courts/Select
%20Committee%20Report.pdf
4

beyond the pleadings. There is a lot of litigation in this area as to the scope
and extent of the liberty to amend the pleadings. In the Common law, the
pleading practice was a mechanical and rigid exercise such that misspellings
of minor details were not allowed.3 The object and purpose of the pleadings
is to make the opposite party acquaint with the case he has to face in the
due course of time. The whole object of the pleadings is to bring parties to
the definite issues, reduce costs and to ensure the speedy delivery of justice.
This also results in the conduct of the fair and flawless trial and the pleadings
must contain all the essential material facts so that the adversary party is
not taken away by surprise. The parties are normally expected to confine to
the pleadings.
One of the most important objects of allowing the amendment to pleadings is
to prevent multiplicity of suits. If the amendment is sought seeking an
ancillary relief is not allowed, then the party might have a remedy to raise
the same in the subsequent case. The amendments relating to
constructive res judicata must not be allowed by the courts.

Interpretation
Order VI, Rule 17 of the Code of Civil Procedure provides for the
Amendment of pleadings. The provision enumerates that a court may
allow any party at any stage to amend the proceedings if it considers that to
be just. All such amendments which are necessary for the purpose of
determining the real questions in controversy between the parties shall be
made by the court. A proviso has been added to this provision through the
CPC (Amendment) Act, 1999, which intends to limit the powers of the courts
discretion of amendment of pleadings. It says that no application for the
amendment shall be allowed by the court after the commencement of the
trial, unless the court is of the opinion that notwithstanding the parties due
diligence, they could not have raised the matter before the commencement
of the trial.
Rule 16 of the same Order provides for the striking out of the pleadings.
This was also subjected to the amendment in the year 1976. It provides that
the Court may at any stage of the proceedings order to amend or remove
any part of the pleading which is unnecessary, scandalous, frivolous or
3 Holdsworth, THE HISTORY OF THE ENGLISH LAW 305 (1923).
5

vexatious etc. The Court may also modify at any stage any matter that
delays the fair trial or abuses the process of the court.
The rules of interpretation to be followed in interpreting this provision are
very simple. The provision can be divided into two parts. The first part is
discretionary (may) and gives wide and unfettered discretion to decide on
case-to case basis whenever it appears to be just. The court may or may not
allow the amendment to the proceeding for determining the real questions of
controversy. The approach of the Court should be liberal and not
hypothetical4. Hence, the amendment to proceedings is not a right; rather it
is in the discretion of the court.
The second part is mandatory (Shall) and orders the court to accept all the
applications necessary for the purpose of determining the real issue between
the parties if it finds that the parties could not have raised the issue in spite
of the due diligence before the commencement of the trial. However, such
discretion must be exercised by applying the judicial mind according to the
well-established principles.

Object of the rule

The primary object of the rule is that the Courts should try the case based on
the merits and should subsequently allow the amendments which are must
for assessing the real controversy between the parties. This ensures that the
injustice is not caused to the either side based on minute omissions by the
parties. The Supreme Court in the case of Haridas Girdhardas vs.
Vasadaraja Pillai5 held that however negligent or careless the first
omission may have been, and however late the proposed amendment, the
amendment should be allowed if it does not cause any injustice to the other
side.
A suit must be instituted before the remedy under this rule is availed. The
Supreme Court through Jai Jai Ram Manohar vs. National Building

4 Narayana Pillai vs. Parameshwaran Pillai, AIR 2000 SC 614.

5 AIR 1971 SC 2336.
6

Material Supply6 expressed that courts are meant for the purpose of doing
justice and not for punishing them for minor mistakes.
The object underlying the amendment of pleadings was laid down by Bowen,
L.J, in the case of Cropper vs. Smith7 Now, I think it is a well-established
principle that the object of Courts is to decide the rights of the parties, and
not to punish them for mistakes they make in the conduct of their cases by
deciding otherwise than in accordance with their rights. Speaking for myself,
and in conformity with what I have heard laid down by the other division of
the Court of Appeal and by myself as a member of it, I know of no kind of
error or mistake which, if not fraudulent or intended to overreach, the court
ought not to correct, if it can be done without injustice to the other party.
Courts do not exist for the sake of discipline, but for the sake of deciding
maters in controversy, and I do not regard such amendment as a matter of
favor or of grace.

Nature and Scope

The concept of amendment of pleadings can be traced back to the decision
of the Privy Council in the case of Ma Shwe Mya vs. Maung Mo
Huang.8 The Court observed that the rules of Courts are nothing but
provisions intended for securing the ends of justice and all those rules must
be subordinate to achieve that purpose. For that to be achieved, full powers
of amendment must be enjoyed and liberally exercised by the courts and it
has added a caveat that an amendment cannot be made to substitute one
cause of action for another.
Order I, Rule 10 confers the power to the court either to add or strike off a
party to the suit. The right of the court either to add or subtract the parties
can be exercised either suo moto or by an application of the party.
The situations wherein the amendments to the pleadings should or should
not be allowed cannot be laid down by a court of law in a straight jacket
formula. It must be decided on case-by-case basis. However, this rule applies
6 AIR 1969 SC 1267.
7 (1884) 29 Ch D 700.
8 AIR 1922 PC 249.
7

to other proceedings such as execution proceedings, arbitration proceedings,

petitions under Special Marriage Act etc.

Leave To Amend When Granted

The general rule is that the leave to amend will be granted so as to enable
the real question on issue between the parties to be raised in the pleadings,
where the amendment does not cause any injury to the opposite party9 .
Now let us look at the approach of the judiciary in solving this issue. This job
helps us in tracing the evolution of the law relating to the amendment of
proceedings.
Generally, the courts grant the leave to amend the proceedings if such
allowance enables the court to decide the real matter in controversy.
Provided that, it does not cause injustice to the other party. In Suraj
Prakash vs. Raj Rani10, the Supreme Court held that liberal principles
should guide the court in the exercise of discretion in allowing amendment. It
said that the multiplicity of proceedings should be avoided and the
amendments which might change the character of the case must not be
allowed. It also added a caveat that the subject matter of the suit must not
be changed by that.
Though the courts were granted unfettered discretion to decide whether to
grant the amendment or not, but it is subjected to misuse. The classic rule is,
the wider the discretion, the greater the misuse. This power of the courts
must be exercised properly, reasonably and non-arbitrarily.
The amendment can be simply refused when it is not necessary to determine
the real question in controversy. The leading decision on this point is Edwian
vs. Cohen11. In this case, As furniture was wrongfully removed by B and C.
A filed a suit against B for damages and later he sued C for the same wrong.
Later, C sought an amendment that judgment against B is bar against the
suit against him. The application was rejected as it was not necessary to
decide the real issue in controversy.
9 Tildersay vs. Harper, (1878) 10 Ch D 393.
10 AIR 1981 SC 485
11 1889) 43 Ch D 187.
8

Introducing New and Different case

The application to amend will be rejected if that seeks to introduce new and
different case.Steward vs. North metropolitan Tramways Company12.
In this case, the plaintiff filed a suit against the company for negligence in
running the tramways in defective condition. It was not contended that the
company was not the proper party to be sued. Six months later, the
company made an application that the duty to maintain the tramways is in
the jurisdiction of the local authority under the contract. At the time of
amending the application, the remedy against the local authority was time
barred. Had the agreement been shown earlier, the plaintiff would have sued
the local authority. In the present case, the amendment was rejected and the
company was held liable. This case laid down the rule that if the amendment
of the written statement wholly displaces the position of the plaintiff, then
the amendment should not be allowed.
Taking away the right accrued to the other side by lapse of time
In K. Venkateswara Rao vs. B.N. Reddi13, the Supreme Court held that
the courts have wide powers to amend the plaint under Order VI Rule 17,
but those powers are subject to Law of Limitation. Material facts and
important particular must be included in the pleadings based on which the
Court ventures ahead to decide the suit. But, most of the times, the parties
find it inconvenient not to amend the pleadings. They seek to adduce new
evidence, to add fresh information, which are exclusively gathered by them.
It might be a case where one party must amend the pleadings in view of the
documents disclosed by the opposite party, thus chiseling his claim or
defense.
The application to amend will be refused if it proposes to take away the legal
rights of the other party accrued in his favour. The English case on this
subject is Weldon vs. Neal14 In this case, A filed a suit against B for slander.
Later, he sought to amend the plaint adding the additional charges of assault
12 1886) 16 QB 178.
13 AIR 1969 SC 872
14 (1880) 19 QBD 394.
9

and false imprisonment. But, they were barred by limitation on the date of
application. This proposed amendment was refused since it would take away
the other partys legal right i.e the defense under the law of limitation.
This particular rule is not a universal one but is subjected to certain
restrictions as dealt in the above chapter. The Privy Council in Charan Das
vs. Amir Khan15 held that the courts no doubt have undisputed power to
amend the pleadings, but there are situations where the questions of law of
limitations are outweighed by the special circumstances of the case. In this
particular case, the plaintiffs sued the defendants and claimed only the title
of over the disputed property, but they did not claim consequential relief of
possession. Hence, Privy Council, even though the application was submitted
after the limitation period expired, accepted it holding that there is no
ground where the plaintiffs could have acted with mala fide intention.
The case of Kishan Das vs. Rachappa 16 was one where the amendment
was allowed on the ground that circumstances of the case are very particular
that it should be considered as an exception to the general rule. The facts
are that A alleging that he brought a capital of Rs. 4000 to the partnership
firm operated with B and sues for dissolution of partnership and the
accounts. After the examination of the proceedings in the court of first
instance by the Bombay High Court, it felt that A initially intended to plead
for recovery of money and not dissolution. Here, the evidence was taken and
the issues were framed only with reference to the recovery of money. The
same court refused to allow the amendment as it found that the agreement
between A and B does not constitute partnership. Later, he appeals from that
decree seeking to amend the plaint but at that date, the laws of limitation
came into action. The Court felt that the amendment should be allowed for
the point of limitation could not have been taken if the pleading was not
defective. The other amendments which cannot be allowed by the court of
law are the ones forbidden by law and the ones which are not bona fide.
For instance, in Shiv Gopal Shah vs. Sita Ram Sarongi17 , the case was
that the defendant set up the claim of rival title on the basis of sale of
property through sale deed. The plaintiffs along with co-plaintiffs, remained
15 AIR 1921 PC 50.
16 4 Ind Cas 726.
17 AIR 2007 SC 1478.
10

silent for more than 15 years after getting the sale deed of the defendant
stating that it is bogus. The Supreme Court refused to entertain their claim
as it found that to be time barred. The Court found that the delay was very
substantial and that the plaintiffs were negligent. The court laid down a rule
that there has to be valid explanation and basis made out in the application.
The proceedings cannot be amended if the party introduces a new case or
lets in new evidence and if the court feels that the amendment leads to
unnecessary complications. The court may refuse to allow the amendment if
it feels that the party had several opportunities and had slept over his rights.
The amendment in a pleading cannot be claimed as a matter of right18.
While considering the application for amendments should or should not be
allowed, the courts should not go into the correctness or falsity of the case in
the amendment. When the amendment application is accepted by the court,
then normally an opportunity should be given to the opposite party to file
objections of the same. But of the amendment is formal in nature, then the
notice is not necessary.

Interpreting at any stage of proceedings

Under Order 6, Rule 17, the courts were given power to amend the
proceedings at any stage of the proceedings which simply means that the
amendment applications are not governed by the law of
limitations Narayana Pillai vs. Parameswaran Pillai19 . The object of
inserting such clause is to serve the ends of justice by determining the exact
controversy between the parties. The court may accept the application of
amendment before, during or after the trial, after the decree, in first appeal
or in the second appeal or in the revision or in the High Court or in the
Supreme Court. That list even extends to the execution proceedings. The
court must keep in mind that complete justice must be done to the parties.
Therefore, delay in making the application is not fatal. But, if there is a gross
delay and latches on the part of the amendment, and if the court feels that
permitting such amendment causes serious prejudice to the other party,

18 Kanda vs. Waghu, AIR 1950 PC 68

19 Vicco Laboratories vs. Hindustan Rimmer, AIR 1979 Del 114
11

which however cannot be compensated in terms of costs, then the courts

may not allow such an amendment.
The Supreme Court in Gauri Shankar vs, Hindustan Trust ltd20 held that
not raiding the plea for the span of eight years, a great prejudice was
caused to the appellant.
The proviso adduced to the provision by way of amendment in 2002
merely limits the power of the court and does not allow the court to allow
amendment after the commencement of the trial unless it comes to the
conclusion that in spite of due diligence, that matter could not be raised by
the party before the commencement of the trial.

Pretrial and post-trial amendments

Re-trial amendments are more liberally allowed the post-trial amendments.
The reason is that in the formal cases, it is assumed that the opposite party
is not said to be prejudiced as he has full opportunity of meeting the case put
forward by his opponent. In the latter cases, the question of prejudice may
arise and must be dealt carefully21.

Doctrine of relation back

If an amendment is incorporated in a pleading, the Court has the power to
direct in appropriate cases that such particular amendment does not relate
back to the date of the institution of the suit in the interest of justice. This
was stated by the Supreme Court in the case of Sampath Kumar vs.
Ayyakanu22. The Supreme Court made it mandatory that the party seeking
to amend the pleading should mention in the application specifically as to
what is to be altered or substituted in the original pleadings. After a close
scrutiny by Court, the Court can in its discretion relate it to the original one.

20AIR 2000 SC 614.

21 AIR 1972 SC 2091
22 AIR 2002 SC 3369
12

In Sjjan Kumar vs. Ram Kishan23, the question was whether to permit the
amendment relating to the mis-description of the suit. The claim was that
the description given about the rent note was wrong and it was repeated in
the plaint and this was after the commencement of the trial. Here, the
Supreme Court stated that notwithstanding that the application to
amendment was proposed after the commencement, the proposed
amendment is needed for bringing into the fore the real controversial
between the parties. The Madras High Court in the case of Hi Sheet
Industries vs. Litelon Ltd24 said that the proviso to the rule is applicable
only to the pleadings instituted with effect from 01-07-2002 and not in prior
to this.
The Supreme Court in the case of Laxmidas vs. Nanabai25 explained the
law on the amendment of the pleadings. It said that the court can refuse to
entertain the application for amendment if it feels that it restraints the other
partys legal rights which are accrued to him by lapse of time. But, it said
that this rule could be applied only when fresh allegations are added by the
process of amendments and not in the cases where amendments are sought
to clarify an existing pleading where it does not add or subtract any
substantial material relevant to the proceeding. Hence, the law before the
1999 amendment was that the court has unlimited power of allowing the
amendments to be made in the cases where it merely clarifies the original
pleading. Hence, in a case of mis-description of plaintiff, the plaint can be
amended at any time for the purpose of rectifying it and the question of
limitation does not arise in that case.

Amendment to written statements

The principles that apply to amendments of pleadings also apply to the
written statements. The Supreme Court in Usha Balasahed Swami vs.
Kiran Appaso Swami26.explained the law relating to the applicability of law
23 (2005) 13 SCC 89.
24 AIR 2007 Mad 78.
25 AIR 1964 SC 18.
26 AIR 2007 SC 1663.
13

relating to amendment of pleadings to the amendments of written

statements. It said that the prayer relating to the amendment to the plaint
and that of written statements stand on different levels. The general
principle is that amendments should not be allowed which substitute a cause
of action in the nature of the claim. The Supreme Court said that there is no
counterpart in the principles relating to the amendment of the written
statement. Hence, the Court said that addition or substitution of written
statement would not be objectionable whereas adding or subtracting the
cause of actions by the plaint may be objectionable.
Hence the Apex Court in this case held that the courts should be more liberal
in allowing the applications for the amendment of the written statements
that in the case of plaints as question of prejudice would be more in the
former case.

Amendments based on subsequent events

The question which always perturbed the judicial minds is whether
amendments can be allowed on the basis of events which happened
subsequent to the suit. The law is well settled that though the rights of the
parties have to be decided on the date of the suit, the courts can in the
interest of the justice take notice of the subsequent events and make
appropriate amendments. The Andhra Pradesh and Madras High Courts have
said that applications for amendments which seek to oust the jurisdiction of
the courts must not be allowed.

Effect of 2002 Amendment

On the recommendation of the law commission, the CPC was amended in
2002, limiting the power of courts in granting the amendments after the
commencement of the trial. With the intention of shortening the litigation
and for the speedy disposal of the cases, RULE 17 was omitted by the 1999
amendment. The legislators felt that this rule was in the statute book since
ages and there is no single case where this rule was not used. The provision
was restored back in 2002 in view of the protests, agitations and strikes all
over the country, but with a caveat in the form of the proviso. The new
proviso provides that no application for amendment must be processed by
the court after the commencement of the trial, unless the courts come to the
14

conclusion that in spite of the due-diligence of the parties, they could not
have raised before the commencement. But, the issue of deciding whether
the parties in spite of due diligence could have raised the prayer or not
depends on the facts and circumstances of the each case. This amendment
is trying to limit the powers of the court to some extent, nonetheless, the
courts have unfettered powers in the cases of the unforeseen situations.
This provision has been already subjected to the judicial scrutiny by the
courts in India. The Andhra Pradesh High Court in the case of E. Prasad
Goud vs. B. Lakshamana Goud27 held that the proviso is not a complete
bar nor shuts out entertainment of any later application if the court finds that
a party in spite of due diligence could not raise the plea. The Supreme Court
in the case of Salem Advocate Bar Association, Tamil Nadu vs. Union
of India28 upheld the validity of the provision and said that its object is to
prevent frivolous applications filed to delay the process of trial. The Supreme
Court in Baldev Singh case held that the term commencement of the trial
must be used in limited sense as meaning final hearing of the suit,
examination of the witnesses, filing of the documents and addressing the
documents.
In Sampath Kumar vs. Ayyakannu29 , the plaintiff filed a suit against the
defendant for prohibitory injunction. But, before the commencement of the
trial, he was dispossessed of the property and after eleven years, he moved
an application seeking amendment of the plaint claiming possession. The
defendant claimed that this would change the nature of the suit and thathe
had the perfect title by adverse possession and this particular claim is barred
by law of limitation. The trial court and the high court rejected the
application of the plaint but the Supreme Court allowed it saying that: We
fail to understand, if it is permissible for the plaintiff to file an independent
suit, why the same relief which could be prayed for in the new suit cannot be
permitted to be incorporated in the pending suit.
The court also placated the defendant by saying that in the interest of the
defendant, the new reliefs sought for are considered by the court to be
27 (2003) 3 Andh LT (386).
28 AIR 2005 SC 3353.
29 2002 Supp (2) SCR 397.
15

deemed to be made on the date on which the application seeking

amendment was filed
In another interesting case Nagappa vs. Gurdayal Singh30, the facts are
that plaintiff suffered injuries in an accident and filed an insurance claim of
one lakh. But, in the Apex Court he enhanced his claimed to five lakh. The
Supreme Court granted him relief stating that when there is sufficient
evidence on record justifying the enhanced compensation for medical
treatment, the same should be granted. In this type of cases, the court said
that there is no question of introducing a new or inconsistent cause of action.
Hence, the courts, in case they want to do justice to the parties, do not
consider themselves to be restricted by any legislation.

CONCLUSION
The law of amendment of pleadings is settled by the Supreme Court. The
Courts started with the rule of law that there must not be any restriction on
the powers of the courts be it law of limitation or after the commencement of
the proceeding, for securing the ends of justice and to minimize the harm
caused to the opposite party. The Courts have been very active in this area
30 AIR 2003 SC 674.
16

developing the law time and again to suit to the various time frames.
However, the legislators themselves thought that discretion should be
granted to the courts whether to allow the amendment or not to decide the
matter in issue. The courts themselves since 1908 have started crystallizing
the law through guidelines which must be followed while allowing the
amendments. They have laid down the principles in which the leave to
amendment should be granted and the cases in which it should not be.
However, the Supreme Court has been cautious and vigilant in carefully
designing the guidelines to be followed by the lower courts. Gradually, as a
lot of discretion is vested on the courts, there is a possibility of misuse. There
was a Law Commission Report stating that this provision of the amendment
was used on a large scale and hence it needs to be restricted.
In 1999, efforts were made to eliminate this provision but could not be
brought into force. Due to a lot of protests from the legal practitioners, this
was restored back in the 2002 CPC Amendment. But, now a small caveat was
adduced to the proviso with a view to limit the unrestrained power of the
courts in allowing or refusing the amendments. This was that the court shall
allow the amendments to the pleadings only if it feels that the parties could
not have raised before in spite of their due diligence. By the literal reading of
the provision, it appears that that the power of the Courts is restricted. But, a
simple glance at the judgments pronounced since 2002 discussed in the
above sections shows that the Courts continued to exercise the unbridled
power even after the amendment for securing the ends of justice. This is
bold judicial activism that has reached great heights and did not erode the
faith entrusted by the citizens in the judiciary.

BIBLIOGRAPHY

17

BOOK SOURCES:

Takwani C.K, Civil Procedure with Limitation Act,1963 ; Eastern Book

Company,Lucknow, 2015.
Mulla; The Code of Civil Procedure Lexis Nexis Butterworths
Publications (17th edn.), 2007.
Bare Act, The Code of Civil Procedure Code 1908,Universal
Publications,2015.

WEB SOURCES:

https://civillawyersindia.wordpress.com/2012/12/24/amendment-inplaint-under-order-vi-rule-17-of-cpc/
http://www.mondaq.com/india/x/247576/Civil+Law/AMENDMENT+OF+P
LEADINGS+AN+OVERVIEW
http://www.legalservicesindia.com/article/article/amendment-topleadings-and-the-approach-of-the-judiciary-1427-1.html

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