EMERGING JUDICIAL PROCEDURE FOR REVIEW PETITIONS

UNDER SECTION 114 OF CODE OF CIVIL PROCEDURE, 1908

Submitted to:
Mr. V. Surya Narayan Raju
(Assistant Professor, Code of Civil Procedure)

Submitted by:
Prashant Choudhary
Roll No.: 110
B.A. L.L.B. (HONS.)
Semester: IX
Section: C

Date of Submission: 18.08.2018

HIDAYATULLAH NATIONAL LAW UNIVERSITY

Uparwara Post, Abhanpur, New Raipur – 492002 (C.G.)
 DECLARATION

I hereby declare that the project work entitled “Emerging Judicial Procedure for Review
Petitions under Section 114 of Code of Civil Procedure, 1908” submitted to Hidayatullah
National Law University, Raipur, is a record of an original work done by me under the able
guidance of Mr. V. Surya Narayan Raju, Assistant Professor, Code of Civil Procedure,
Hidayatullah National Law University, Raipur.

Prashant Choudhary

Roll No.: 110

Section: C

Semester: IX

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 ACKNOWLEDGEMENTS

I feel highly elated to work on the topic “Emerging Judicial Procedure for Review Petitions
under Section 114 of Code of Civil Procedure, 1908”. This research venture has been made
possible due to the generous co-operation of various persons. To list them all is not practicable,
even to repay them in words is beyond the domain of my lexicon.

May I observe the protocol to show my deep gratitude to the venerated Mr. V. Surya Narayan
Raju, Assistant Professor, for his kind gesture in allotting me such a wonderful and elucidating
research topic. His consistent supervision, constant inspiration and invaluable guidance have
been of immense help in understanding and carrying out the nuances of the project report.

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 TABLE OF CONTENTS

DECLARATION ....................................................................................................................... 1
ACKNOWLEDGEMENTS ....................................................................................................... 2
1. INTRODUCTION ............................................................................................................. 4
Hypothesis .......................................................................................................................... 5
Research Questions ............................................................................................................. 5
Objectives ........................................................................................................................... 5
Research Methodology ....................................................................................................... 5
Scope of Study .................................................................................................................... 6
Review of Literature ........................................................................................................... 6
2. AN INTRODUCTION TO REVIEW IN THE CONTEXT OF SECTION 114 ............... 7
2.1. Meaning of Review ..................................................................................................... 7
2.2. Nature and Scope of Review ....................................................................................... 7
3. WHO MAY SEEK REVIEW UNDER SECTION 114? ................................................... 9
4. CIRCUMSTANCES IN WHICH REVIEW LIES .......................................................... 10
4.1. Where no appeal lies ................................................................................................. 10
4.2. Where appeal lies but is not preferred ....................................................................... 10
4.3. Decisions on reference from Courts of Small Causes ............................................... 10
5. GROUNDS FOR REVIEW ............................................................................................. 10
5.1. Discovery of new and important matter or evidence ................................................ 11
5.2. Error apparent on the face of the record .................................................................... 11
5.3. Erroneous decisions vis-à-vis error apparent on the face of the record .................... 12
5.4. Mistake on the part of the court ................................................................................ 12
5.5. Other sufficient reason .............................................................................................. 13
6. WHO MAY ENTERTAIN A REVIEW PETITION? ..................................................... 13
7. INHERENT POWER OF COURT TO REVIEW ........................................................... 14
7.1. Court of plenary jurisdiction ..................................................................................... 14
7.2. Suo Motu Review ...................................................................................................... 14
8. PROCEDURE FOR REVIEW ........................................................................................ 15
8.1. First Stage.................................................................................................................. 15
8.2. Second Stage ............................................................................................................. 15
8.3. Third Stage ................................................................................................................ 15
9. CONCLUSION ................................................................................................................ 16
BIBLIOGRAPHY .................................................................................................................... 17

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 1. INTRODUCTION
The Civil Procedure code has granted the right of review, but this right has been made subject
to procedure, conditions and limitations, which have been prescribed in rules of Order XLVII
of the Civil Procedure Code. The right of review is a substantive right, the main object of which
is to enable the courts to correct errors, in the decisions pronounced by them. If the decree or
an order or made on the basis of some record and there has been some mistake or error apparent
on the face of record or some new and important matter or evidence is discovered after the
passage of decree or order or another such sufficient reasons, the application of review, may
be made by the aggrieved party.

Dictionary meaning of the word review is an act of carefully looking at or examining the quality
or condition of something or someone: examination or inspection. As per Black’s Dictionary,
a review is “to re-examine judicially. A reconsideration; second view or examination; revision;
consideration for purposes of correction.” Review is to be filed by the aggrieved in the same
court where the order or decree is passed. It is a discretionary right of the court and not a
statutory right.

According to section 114 of CPC, any person aggrieved by a decree or order from which an
appeal is allowed but not filed, or a decree or order from which no appeal is allowed, can file
a review petition in the same court which passed such decree or order. There is not provision
of reviewing an order already reviewed, unlike an appeal where there is a provision of second
appeal. Review is dealt with under Section 114 and Order 47 of CPC. Article 137 of the
Constitution confers powers on the Supreme Court to review its own judgments subject to the
provisions of any law made by Parliament or the Rules made under clause (c) of Article 145.
The power of Supreme Court, therefore, cannot be curtailed by the Code of Civil Procedure.1

1
Ram Singh & Ors. v. Union of India & Ors., AIR 2015 SC 654
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HYPOTHESIS
The provision relating to review under Section 114 of the Code of Civil Procedure, 1908
constitutes an exception to the general rule that once the judgment is signed and pronounced
by the court it becomes functus officio (ceases to have control over the matter) and has no
jurisdiction to alter it.

RESEARCH QUESTIONS
 What are the provisions under the Code of Civil Procedure, 1908, dealing with review
petitions?
 What is the nature and scope of the provisions under the Code of Civil Procedure, 1908,
dealing with review petitions?
 How has the Indian judiciary dealt with and made its observations with regard to the law
governing review petitions?

OBJECTIVES
 To study the legal framework and highlight specific provisions under the Code of Civil
Procedure, 1908, dealing with review petitions.
 To discuss the nature and scope of the abovementioned provisions.
 To enumerate various decisions and observations made by the Indian judiciary from time
to time with regard to law governing review petitions.

RESEARCH METHODOLOGY
The mode of writing this research paper is doctrinal in nature. Secondary and Electronic
resources have been largely used to gather information and data about the topic. Books and
other reference as guided have been primarily helpful in giving this project a firm structure.
Websites, dictionaries and articles have also been referred. Footnotes have been provided
wherever needed, to acknowledge the source.

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SCOPE OF STUDY
The scope of study of the concerned project is limited to analysing the resort to Section 114 of
the Code of Civil Procedure. Recent judgments with regards to the review of petitions and the
dynamic understanding of the same have tried to be examined as well. However, due to paucity
of time, it was not possible to analyse the same in an explicit and detailed manner.

REVIEW OF LITERATURE
 Mulla The Code of Civil Procedure, 17th Ed., 2007: Being one of the most authoritative
texts on the subject, the book helped to develop an insight into the scheme of the CPC and
served as one of the starting points of this research with its vast collection of landmark
precedents.
 C.K. Takwani, Civil Procedure with Limitation Act, 1963, 8th Edition, 2017: The book
provided substantial information on the nature of procedural laws in a lucid manner. While
the CPC does not expressly deal with the subject, the book tries to lay down the law as
interpreted by various courts.

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 2. AN INTRODUCTION TO REVIEW IN THE CONTEXT
OF SECTION 114
S. 114 of the Code gives a substantive right of review in certain circumstances and Order XLVII
provides the procedure thereof. The provision relating to review constitutes an exception to the
general rule that once the judgment is signed and pronounced by the court it becomes functus
officio (ceases to have control over the matter) and has no jurisdiction to alter it.2

2.1. MEANING OF REVIEW

Review simply means to reconsider or to re-examine. In legal parlance, it is a judicial re-
examination of the case by the same court.

2.2. NATURE AND SCOPE OF REVIEW

The general principle of law is that once a judgment is pronounced or an order is made, the
court becomes functus officio. Such judgment or order is final and cannot be altered or changed,
subject to other provisions of the Code. A review of a judgment is a serious step and reluctant
resort to it is called for only where a glaring omission, patent mistake or like grave error has
crept in earlier by judicial fallibility. Greater care, seriousness and restraint is needed in review
applications. It is neither fair to the court that decided the matter nor to the huge backlog of
cases waiting in the queue for disposal, to file review petitions indiscriminately and fight over
the same battle again which has already been fought and lost.

A right of review is both substantive and procedural. As a substantive right it has to be

conferred by law, either expressly or by necessary implication. There can be no inherent right
of review. As a procedural provision, every court or tribunal can correct an inadvertent error
which has crept in the order either due to a procedural defect or a mathematical or clerical error
or by misrepresentation or fraud of a party to the proceeding, which can be corrected ex debito
justitae (to prevent the abuse of process of court).

Section 114 of the Code of Civil Procedure, 1908 empowers a court to review its order, decree
or decision, as the case may be, if the conditions precedent laid down are satisfied. It does not
lay any fetters on the power conferred on the court by way of this provision, other than those

2
Order XX, Rule 3
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expressly mentioned in the provision. It was held in the case of Board of Control for Cricket,
India v. Netaji Cricket Club3 that the substantive provision of law does not prescribe any
limitation on the power of the court except those which are expressly provided in Section 114
of the Code of Civil Procedure, in terms whereof it is empowered to make such order as it
thinks fit.

It has been held by the Orissa High Court that the mere possibility of two views on the subject
cannot be a ground for review. The court cannot entertain a review petition to find out which
view is correct, in the case of Ghanashyam Sahoo v. Kendrapara Municipality4.

The scope of the power of review under Order XLVII, Rule 1 of the Code is very limited and
the review must be confined strictly only to the errors apparent on the face of the record.
Reappraisal of the evidence on record would amount to exercise of appellate jurisdiction, which
is not permissible by the statute. Review proceedings are not by way of appeal and have to be
strictly confined to the scope and ambit of the aforementioned Rule. Hence review on questions
of fact on the basis of new evidence is not permissible where it is provided that the new
evidence was not available at the time of original hearing.

Appeal v. Review
 An appeal lies to the superior court, while a review lies to the same court.
 Review of a judgment involved reconsideration of the same subject-matter by the same
judge while an appeal is heard by a different judge.
 The grounds of appeal are wider than the grounds of review.
 A second appeal lies on a substantial question of law. A second review application does
not lie.

Reference v. Review
 In a reference it is the subordinate court and not the party which refers the case to the High
Court. In case of a review, the application is made by the aggrieved party.
 The High Court alone can decide matters on reference. On the other hand, review is by the
court which passed the decree or made the order.

3
AIR 2005 SC 592
4
AIR 2006 Ori 69
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 A reference is made, pending a suit, appeal or execution proceedings, while an application
for review can be made only after the decree is passed or order is made.
 The grounds for reference and review are different.

Review v. Revision
 Revisional jurisdiction can only be exercised by the High Court, while the power of review
can be exercised by the very court which passed the decree or made the order.
 Revisional power can be exercised by the High Court only in a case where no appeal lies
to the High Court, but review can be made even when an appeal lies to the High Court.
 Revisional powers can be exercised by the High Court even suo motu, but for review an
application has to be made by an aggrieved party.
 The powers of revision and review can be exercised on different grounds.
 The order granting review is appealable, but an order passed in the exercise of Revisional
jurisdiction is not appealable.

3. WHO MAY SEEK REVIEW UNDER SECTION 114?

The term “any person” under Section 114 and Order XLVII, Rule 1 of the Code does not merely
contemplate a party to a suit or proceeding to seek review, but, it permits any person aggrieved
by the order to seek review. A “person aggrieved” means a person who has suffered a legal
grievance or against whom a decision has been pronounced which has wrongfully deprived
him of something or wrongfully refused him something or wrongfully affected his title to
something. This expression denotes an elastic, and to some extent, an illusive concept. It cannot
be confined within the bounds of a rigid, exact and comprehensive definition.

A person aggrieved has been understood to mean one who has a genuine grievance because an
order has been made which prejudicially affects his interests. However leniently one may
construe the expression, a person not affected directly and immediately cannot be so
considered. A person who is neither party to the proceedings nor a decree or order binds him,
cannot apply for review as the decree or order does not adversely or prejudicially affect him.
But if third party is affected or prejudiced by a judgment or order, he can seek review of such
order. Further, a person who is a necessary party to the suit and yet not joined and the order
passed in such suit affects him, may seek review thereof.
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 4. CIRCUMSTANCES IN WHICH REVIEW LIES
4.1. WHERE NO APPEAL LIES
A decree or order from which no appeal lies is open to review. Hence, where an appeal is
dismissed on the ground that it was incompetent or was time barred, the provisions of review
would get attracted.5

4.2. WHERE APPEAL LIES BUT IS NOT PREFERRED

A review petition is also maintainable in cases where appeal is provided but no such appeal is
preferred by the aggrieved party. The fact that an order is subject to appeal is no ground for
rejection of a review application. An application for review can be presented so long as no
appeal is preferred against the order. However, where an appeal is already instituted before
making an application for review, the court cannot entertain such application. Similarly, where
an application is preferred and is disposed of, no review would lie against the decision of the
lower court. But if an application for review is preferred first and then an appeal is filed, the
jurisdiction of the court to deal with and decide the review petition is not affected. The words
“from which an appeal is allowed” should be construed liberally keeping in mind the
underlying object of the provision that before making a review application, no superior court
has been moved for getting the same relief, so that for one and the same relief two parallel
proceedings before two forums are not taken.6 If review is granted before disposal of the
appeal, the decree or order ceases to exist and the appeal will not remain. Conversely, if the
appeal is decided on merits before an application for review is heard, such petition becomes
infructuous and is liable to be dismissed.

4.3. DECISIONS ON REFERENCE FROM COURTS OF SMALL CAUSES

The Code of Civil Procedure, 1908 allows a review of a judgment on a reference from a Court
of Small Causes.7

5. GROUNDS FOR REVIEW

An application for review of a judgment may be made on any of the following grounds:

5
Ram Baksh v. Rajeshwari Kunwar, AIR 1948 All 213
6
Kabari (P) Ltd. v. Shivnath Shroff, (1996) 1 SCC 690
7
Order XLVII, Rule 1(1)(c)
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(a) Discovery of new and important matter or evidence
(b) Mistake or error apparent on the face of the record
(c) Any other sufficient reason8

5.1. DISCOVERY OF NEW AND IMPORTANT MATTER OR EVIDENCE

A review is permissible on the ground of discovery by the applicant of some new and important
matter or evidence which, after the exercise of due diligence, was not within his knowledge or
could not be produced by him, at the time when the decree was passed. Where a review of a
judgment is sought by a party on the ground of discovery of fresh evidence, utmost care ought
to be exercised by the court in granting it. It is very easy for the party who has lost the case to
see the weak points in his case and he would be tempted to try to fill in the gaps by procuring
evidence which will strengthen it and put a different complexion upon that part.
The underlying object of this provision is neither to enable the court to write a second judgment
nor to give a second innings to the party who has lost his case because of his negligence or
indifference. Hence, a party seeking review must show that there was no remiss on his part in
adducing all possible evidence at the trial.
Additionally, the new evidence must be: (1) relevant, and (2) of such a character that if it had
been given it would have altered the judgment.9
Further, Rule 1 refers to “evidence” or “other matter in the nature of evidence”, and hence
review cannot be granted on the ground of discovery of new points of law or authorities which
show that the decision was not correct, nor can it be granted on the happening of some
subsequent event or change in law.
Before an application of review can be granted, the applicant must establish hat even after
exercise of due diligence, such evidence was not within his knowledge or could not be produced
by him before the court at the time when the decree was passed. There must be sufficient
evidence of diligence in getting all the evidence available.

5.2. ERROR APPARENT ON THE FACE OF THE RECORD

An error apparent on the face of the record cannot be defined precisely or exhaustively, there
being an element of indefiniteness inherent in its very nature. It must be left to be determined
judicially on the basis of the facts of each case. When a court does not apply the provisions of

8
Order XLVII, Rule 1
9
Appa Rao, Re., ILR (1886) 10 Mad 73 (PC)
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the law which on the face of it would apply to a case, the same would be a mistake or error
apparent on the face of the record. However, a mere error of law is not a ground for review.
Only a manifest error would be a ground for review.10

5.3. ERRONEOUS DECISIONS VIS-À-VIS ERROR APPARENT ON THE FACE OF THE RECORD
There is a clear distinction between an erroneous decision and an error apparent on the face of
the record. The first can be corrected by a higher forum while the latter can only be corrected
by exercise of the review jurisdiction. A review petition has a limited purpose and cannot be
used as an appeal in disguise. A review court cannot act as an appellate court. An error on the
face of the record means an error which strikes one by merely looking at the record and would
not require any long drawn process of reasoning.
In a situation where a statement appears in the judgment of a court that a particular occurrence
happened or did not happen before it, ordinarily it ought not to be permitted to be challenged
by a party, unless both the parties to the litigation agree that the statement is wrong, or the court
itself admits that the statement is erroneous. In such a situation, the remedy available to the
party aggrieved is that of review.
In Uma Addhya v. Biren Mondal11, the order of probate granted by the Probate court was
recalled by the appellate court in view of the compromise between the parties without arriving
at its own conclusion. The court held that the order suffered from error apparent on the face of
the record and was liable to be reviewed.

5.4. MISTAKE ON THE PART OF THE COURT

A mistake on the part of the court may also call for a review of the order. An application would
also be maintainable if there exist sufficient reasons therefore. What constitutes “sufficient
reason” depends on the facts and circumstances of the case. The words “sufficient reason” in
Order XLVII, Rule 1 are wide enough to include misconception of fact or law by a court.
Application for review would be maintainable not only upon discovery of new and important
piece of evidence or when there exists an error apparent of the face of the record, but also if
the same is necessitated on account of some mistake, or for any other sufficient reason.

10
Explanation to Rule 1 clarifies the fact that the decision on a question of law on which the judgment of the
court is based has been reversed or modified by the subsequent decision of a superior court in any other case,
shall not be a ground for review of such judgment.
11
AIR 2006 Cal 200
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In the case of N. Anantha Reddy v. Anshu Kathuria & Ors.12, the Apex Court held that review
on the ground of discovery of new and important matter or evidence can be taken into
consideration if the same is of such a nature that if it had been produced earlier, it would have
altered the judgment under review and Court must be satisfied that the party who is adducing
the new ground was not having the knowledge of the same even after exercise of due diligence
and therefore, it could not be produced before the Court earlier.

5.5. OTHER SUFFICIENT REASON

The expression “any other sufficient reason” has not been defined in the Code. The following
have been held by various courts to be sufficient reasons for granting review:
 Where the statement in the judgment is not correct;
 Where the decree or order has been passed under the misapprehension of the true state
of circumstances;
 Where a party had no notice or fair opportunity to produce his evidence;
 Where the court had failed to consider a material issue, fact or evidence;
 Where the court has omitted to notice or consider material statutory provisions.

6. WHO MAY ENTERTAIN A REVIEW PETITION?

Review is reconsideration of the same subject-matter by the same court and by the same judge.
If the judge who has decided the matter is available, he alone has the jurisdiction to consider
the case and review the earlier order passed by him. Such judge is best suited to remove any
mistake error apparent on the face of his own order. Moreover, he alone will be able to
remember what was earlier argued before him what was not urged. Therefore, the law insists
that if he is available, he alone should hear the review petition.

However, in certain situations this may not be possible. Sometimes the same judicial officer
may not be available. Unexpected and unavoidable causes like death could prevent the judge
who passed the order from entertaining the petition. Such exceptional cases are only allowable
ex necessitate and in those cases, his successor or any other judge or court of concurrent
jurisdiction may hear the review petition and decide on the same.13

12
2013 (14) SCALE 585
13
Reliance Industries Ltd. v. Pravinbhai, (1997) 7 SCC 300
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 7. INHERENT POWER OF COURT TO REVIEW
The power of review is not an inherent power. It must be conferred by law, either expressly or
by necessary implication. If there is no power of review the order cannot be reviewed. In such
cases, the question, whether the order is correct or valid in law does not arise for consideration.
However, it is the duty of the court to correct grave and palpable errors committed by it.
This principle applies to courts, tribunals, quasi-judicial authorities, or administrative
authorities exercising quasi-judicial powers. However, this principle does not have application
in decisions of purely administrative character.14 The administration cannot be hidebound by
rules and restrictions of judicial procedure though are bound to obey statutory provisions and
also observe the principles of natural justice where rights of parties are affected. Finally, the
decisions of the Government are subject to judicial review and may be questioned in a
competent court on all available grounds.

7.1. COURT OF PLENARY JURISDICTION

A court of plenary jurisdiction, like a writ court, has inherent power to review its orders to
prevent the miscarriage of justice or to correct grave and palpable errors committed by it. 15 It
is the final court of the country. It has the last opportunity to verify doubts and to undo injustice,
if any, which might have occurred in the earlier order. In appropriate cases such power may be
exercised suo motu.

7.2. SUO MOTU REVIEW

The power of review can be exercised by a court on an application by a “person aggrieved”.
The Code does not empower the court to exercise the power of review suo motu. 16 It is a settled
principle of law that when a statute requires a particular thing to be done in a particular manner,
it has to be done only in that manner and in no other manner. However, Mukharji J. observed
in the case of R.S. Nayak v. A.R. Antulay17 that the Supreme Court may exercise power of
review suo motu in an appropriate case.

14
C.K. Thakker, Civil Procedure (14th Edition, Lucknow: Eastern Book Company, 2001) at 389.
15
Shivdeo Singh v. State of Punjab, AIR 1963 SC 1909
16
Viswanathan v. M Gounder, AIR 1978 Mad 221
17
(1984) 2 SCC 183
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 8. PROCEDURE FOR REVIEW
An application for review may be divided into the following stages:

8.1. FIRST STAGE

An application for review commences ordinarily with an ex parte application by the aggrieved
party. The court may reject it at once if there is no sufficient ground or may issue rule calling
upon the opposite party to show cause why review should not be granted.18
8.2. SECOND STAGE
The application for review shall be heard by the same court and by the same judge who passed
the decree or made the order unless he is no longer attached to the court, or is precluded from
hearing it by absence, or other cause for a period of six months after the application.19 If the
rule is discharged, the case ends and the application will be rejected. On the other hand, if the
rule is made absolute, the application will be granted for rehearing of the matter.20
8.3. THIRD STAGE
The matter will be reheard on merits by the court either at once or at any time fixed by it. After
rehearing the case, the court may either confirm he original decree or vary it.21

The effect of allowing an application for review is to recall the decree already passed. Any
order made subsequently whether reversing, confirming or modifying the decree originally
passed will be a new decree superseding the original one.

18
Order XLVII, Rule 4
19
Order XLVII, Rule 5
20
Order XLVII, Rule 4(2)
21
Order XLVII, Rule 8
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 9. CONCLUSION
The remedy of review has been borrowed from the courts of equity. The basic philosophy
inherent in the recognition of the doctrine of review is acceptance of human fallibility. If there
is an error due to human failing, it cannot be permitted to perpetuate and to defeat justice. Such
mistakes or errors must be corrected to prevent miscarriage of justice. Rectification of an order
stems from the fundamental principle that justice is above all. It is exercised to remove an error
and not to disturb finality. The normal principle is that a judgment pronounce by the Court is
final, and departure from that principle is justified only when circumstances of a substantial
and compelling character make it necessary to do so. Whatever may be the nature of the
proceeding, it cannot be equated with the original hearing of the case and the finality of the
judgment delivered by the court will not be reconsidered except where a glaring omission or
patent mistake or like grave error has crept in earlier due to judicial fallibility. Section 114
read with O.47, R.1, C.P.C. prescribes the limitations for entertaining a review petition. The
same are: that the party filing the application for review has discovered a new and important
matter or evidence after exercise of due diligence which was not within its knowledge or could
not be produced by it at the time when the decree was passed; or order made or on account of
some mistake or error apparent on the face of the record; or „for any other sufficient reason.‟
The aforesaid limitations are prescribed in a crystal clear language and before a party submits
that it had discovered a new and important matter or evidence which could not be produced at
the earlier stage, the condition precedent for entertaining the review would be to record the
finding as to whether at the initial stage, the party has acted with due diligence. Some mistake
or error, if made ground for review, it must be apparent on the face of the record and if a party
files an application on the ground of „some other sufficient reason‟, it has to satisfy that the
said sufficient reason is analogous to the other conditions mentioned in the said rule i.e.
discovery of new and important matter or evidence which it could not discover with due
diligence or it was not within his knowledge, and thus, could not produce at the initial stage.

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 BIBLIOGRAPHY

BOOKS REFERRED

 D.F. Mulla, The Code of Civil Procedure, 17th Ed., N.M. Tripathi Private Limited,
Bombay (2001).
 C.K. Takwani, Civil Procedure with Limitation Act, 1963, 8th Ed., Eastern Book
Company (2017).

WEBSITES

● www.scconline.com
● www.manupatrafast.in
● www.vakilno1.com
● www.scribd.com
● www.legalserviceindia.com

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