You are on page 1of 20

CHANAKYA NATIONAL LAW UNIVERSITY

RATIFICATION:JUDICIAL INTERPRETATION
Submitted to Dr. Vijay Kumar Vimal
Faculty Of Contracts Law-II

Shubham Mishra
Roll- 1649
2016-2021
3rd Semester
0
[1]

ACKNOWLEDGMENT
I am feeling highly elated to work on under the guidance of my Contracts-II faculty. I am
very grateful to him for the exemplary guidance. I would like to enlighten my readers regarding
this topic and I hope I have tried my best to bring more luminosity to this topic.

I also want to thank all of my friends, without whose cooperation this project was not
possible. Apart from all these, I want to give special thanks to the librarian of my university
who made every relevant materials regarding to my topic available to me at the time of my
busy research work and gave me assistance.
[2]

RESEARCH METHODOLOGY
The method used for research is the doctrinal method and involves research in the library and on
the internet.

Areas of limitations- data of the research study will have its limitations due to the lack of
sufficient financial resources and limited time allotted for the research

AIMS AND OBJECTIVES

• To study the principal-agent relationship.


• To study the concept of ratification.
• To study the essentials of ratification.

HYPOTHESIS

Principal can ratify his agent’s act for those he didn’t authorized him in any cases.

SOURCES OF DATA
•The researcher focusses on obtaining information from both the available sources; they are (1)
primary sources of data, (2) secondary sources of data.

•Primary sources of data include first-hand information available, like journals, district plan
goals, etc. and secondary sources include magazines, journals, etc.
[3]

Table of Contents
PRINCIPAL AND AGENT............................................................................................................ 4
Difference between agency and dealership................................................................................. 4
Creation of an agency ................................................................................................................. 5
RATIFICATION............................................................................................................................. 7
CONDITIONS FOR VALID RATIFICATION ....................................................................... 10
Validity Of Consent In The Agreements Which Are Subject To Ratification ......................... 11
Validity Of Minor’s Contract And State Liability For The Act Of Their Officers .................. 12
In Minor’s case ..................................................................................................................... 12
State liability for the act officers ........................................................................................... 13
Ratification after principal’s death........................................................................................ 13
CASE LAWS ................................................................................................................................ 14
CONCLUSION ............................................................................................................................. 18
BIBLIOGRAPHY ......................................................................................................................... 19
[4]

PRINCIPAL AND AGENT


In India, the agent and principle share a relationship that is contractual in nature, and therefore it
is governed by the terms and conditions of the contract between them. Chapter X of the Indian
Contract Act, 1872 provides the basic structure of rules and regulations that basically govern the
performance and formation of any type of contract including the agency contract.

In agency contracts, there exists a legal relationship between two people whereby one person acts
on behalf of the other. The person acting on behalf of the other is called an agent, and the person
from whom the agent derives authority to act is called the principal. The law of agency is based
on the Latin maxim “qui facit per alium, facit per se,” which means, “he who acts through another
is deemed in law to do it himself”. Agent and principal are defined under Section 182 of the Indian
Contract Act, 1872. According to the section “an agent is a person employed to do any act for
another or to represent another in dealings with third persons. The person for whom such act is
done, or who is so represented, is called the principal”.

The competent agent is legally capable of acting for the principal vis-à-vis the third party. Now
who can become an agent? Section 184 answers this question. According to this section any person
can become an agent i.e. there is no need to have a contractual capacity to become an agent.
Therefore, a minor can also act as an agent. But the minor will not be responsible to his principal.
Different types of commercial agents have been identified under Indian law like brokers,
auctioneers, del credere agents, persons entrusted with money for obtaining sales and insurance
agents.1

Difference between agency and dealership


In the law of agency, the relationship that matters the most between an agent and the principal is
the legal relationship. A person cannot become an agent of another merely because he gives advice
to the other. Any person acting on behalf of the other cannot be an agent for another until there is
an implied or explicit agreement between them, which leads to a legal relationship between them.
Also not all those who describe themselves as agents will, in law, be considered as agents. The
dealer of a particular make of cars, e.g. Mercedes, may be called as an agent, but the dealer in law
is not an agent for the manufacturer. This is because, in practice, the dealer purchases vehicles

1
Contracts-II by R.K Bangia, page no.103
[5]

from the manufactures and sell them on the dealer’s own account. No privity of contract exists
between the manufacturer and the buyer. This example highlights the difference between agency
and dealership. An agent markets his principal’s products for a fixed commission, which can be
determined according to the contracts. But, a dealer buys the product of a company directly from
its manufacturer on its own name. So, rather than matching up the principal and the third party,
the dealer acts as a principal and buys or sells stock for the dealer’s own inventory. An agent acts
as an intermediary and receives a commission for its services. But, a dealer acts on behalf of the
firm rather than acting as an intermediary. As mentioned in the above car example, no contract
exists between the dealer and the manufacturer, thus, there is no legal relationship, which is the
most important thing in the law of agency.2

Creation of an agency
• Agency by Express agreement: Number of agency contract come into force under this
method. It may be Oral or documentary or through power of attorney.
• Agency by operation of law: At times contract of agency comes into operation by virtue
of law.
For example: According to partnership act, every partner is agent of the firm as well as
other parties. It is implied agency. On account of such implied agency only a partner can
bind over firm as well as other partners, to his activities. In the same way according to
companies act promoters are regarded as agents to the company
• Agency by Ratification: Ratification means subsequent adoption of an activity. Soon after
ratification principal – agent relations will come into operation. The person who has done
the activity will become agent and the person who has given ratification will become
principal.
Ratification can be express or implied. In case where adoption of activity is made by means
of expression, it is called express ratification. For example: Without A`s direction, B has
purchased goods for the sake of A. There after A has given his support (adoption) to B`s
activity, it is called Ratification. Now A is Principal and B is agent.
The ratification where there is no expression is called implied ratification. For example:
Mr. Q has P`s money with him. Without P`s direction Q has lent that money to R. There

2
www.lawjournal.com
[6]

after R has paid interest directly to P. Without any debate P has taken that amount from R.
It implies that P has given his support to Q`s activity. It is implied ratification.
• Agency by implied authority: This type of agency comes into force by virtue of
relationship between parties or by conduct of parties.
For example: A and B are brothers, A has got settled in foreign country without any request
from A, B has handed over A`s agricultural land on these basis to a farmer and B is
collecting and remitting the amount of rent to A. Here automatically A becomes principal
and B becomes his agent. Agency by implied authority is of three types as shown below;

Agency by Necessity: At times it may become necessary to a person to act as agent to the other in
emergency situation where the property or interest of another is in danger . the conditions which
enables a person to act as an agent of another in necessity are as follows:

There should be a real necessity for acting on behalf of the principal. It should be impossible to
communicate with the principle within the time available. The alleged agent should act bonafide
in the interest of the principal. For example: A has handed over 100 bags of butter for
transportation, to a road transport company. Actually it is bailment contract assume that in the
transit all vehicles has got stopped where it takes one week for further movement. So the transport
company authorities have sold away the butter in those nearby villages. Here agency by necessity
can be seen.

Agency by Estoppel: Where a person, by his conduct or words spoken or written, willfully leads
another to believe that a certain person is acting as his agency, he is estopped later on from denying
the truth of the fact that such a person is dealing as his agent. Example: In presence of A, B says
to C that he (B) is A`s agent though it is not so actually. A has not restricted B from making such
statement. It is agency by estoppel.

Agency by Holding out: the principal is bound by the act of agent if on an earlier occasion he has
made others believe that other person doing some act on his behalf is doing with his authority.
Example: Y is X`s servant and X has made Y accustomed to bring goods on credit from Z. On one
occasion X has given amount to Y to bring goods from Z on cash. B bought goods on credit as
usually and runs away with the money. This is agency by holding out and therefore X is liable to
pay amount to Z.
[7]

RATIFICATION
Ratification is adopting or accepting subsequently a past act of an agent done on behalf of another
without authority. It is subsequent conformation of unauthorized acts. An agency is created where
a person ratifies or adopts the act of another who without the principal’s knowledge and authority
acted as his agent. Ratification is in law equivalent to previous authority it may be expressed or it
may be affected impliedly by conduct. Section 196 and 197 of the act show that an act done by
person who is not authorized to do it, but who purports to act as an agent for another person, can
retrospectively ratified by such other person. From this it follows logically, that such an act on the
part of the person purporting to act as agent is not void but voidable. If it is not ratified it becomes
void but if it is ratified it will be validated.3

Where acts are done by one person on behalf of other person, but without his knowledge or
authority, but without his knowledge or authority, he may elect to ratify or to disown such acts. If
he ratifies them, the same effects will follow as if they had been performed by his authority as
given in section 196. However, in order that a person may be able to validly ratify an unauthorized
act, the rules of valid ratification must be observed.

The doctrine of ratification comes into play when a person has done an act on behalf of another
without his knowledge or consent. The doctrine gives the person on whose behalf the act is done
an option either to adopt the act by ratification or to disown it. So, it can be derived that ratifications
are either empress or implied. The former are made in express and direct terms of assent; the latter
are such as the law presumes from the acts of the principal.

For example: A, without authority, buys goods for B. Afterwards B sells them to C on his own
account: B’s conduct implies a ratification of the purchase made for him by A.

Ratification is in law equivalent to previous authority it may be expressed or it may be affected


impliedly by conduct. Section 196 and 197 of the act show that an act done by person who is not
authorized to do it, but who purports to act as an agent for another person, can retrospectively
ratified by such other person. From this it follows logically, that such an act on the part of the

3
https://www.legalcrystal.com/cases/search/name:indian-contract-act-1872-section-197-ratification-may-be-
expressed-or-implied
[8]

person purporting to act as agent is not void but voidable. If it is not ratified it becomes void but
if it is ratified it will be validated.

It is doubtful that whether the term “ratification” may properly be applied to the conduct of a
person, who choose to treat as genuine a promissory note on which his signature has been forged.
It is rather on the principal of estoppel that such a person may, under such circumstances render
himself liable. Ratification in order to be effective can only be by an authority that is in existence
on the day of transaction was entered into and it should also be competent to ratify.

So, it can be derived that ratifications are either empress or implied. The former are made in
express and direct terms of assent; the latter are such as the law presumes from the acts of the
principal; as, if Soham buy goods for Rahul, and the latter, knowing the fact, receive them and
apply them to his own use. By ratifying a contract a man adopts the agency; altogether, as well
what is detrimental as that which is for his benefit.

EFFECT OF RATIFICATION

SECTION 196:

Section 196 says where acts are done by one person on behalf of another, but without his
knowledge or authority, he may elect to ratify or to disown such acts. If he ratify them, the same
effects will follow as if they had been performed by his authority.

RATIFICATION MAY BE EXPRESS OR IMPLIED

SECTION 197:

Ratification may be expressed or may be implied in the conduct of the person on whose behalf the
acts are done. A general rule says that, the principal has the right to elect whether he will adopt the
unauthorized act or not. But once doing a ratified act, upon a full knowledge of all the material
circumstances, the ratification cannot be revoked or recalled, and the principal becomes bound as
if he had originally authorized the act. So, the ratification of a lawful contract has a retrospective
[9]

effect on the subject, and binds the principal from its date, and not only from the time of the
ratification, but for the ratification is equivalent to an original authority.4

KNOWLEDGE REQUISITE FOR VALID RATIFICATION

SECTION 198:

No valid ratification can be made by a person whose knowledge of the facts of the case is materially
defective. A general rule of this subject, the principal has the right to elect whether he will adopt
the unauthorized act or not. But once doing a ratified act, upon a full knowledge of all the material
circumstances, the ratification cannot be revoked or recalled, and the principal becomes bound as
if he had originally authorized the act. So, the ratification of a lawful contract has a retrospective
effect on the subject, and binds the principal from its date, and not only from the time of the
ratification, but for the ratification is equivalent to an original authority.

The ratification must be voluntary, deliberate, and intelligent, and the party must know that without
it, he would not be bound to fulfil the obligation.

Therefore such ratification in general meanings relieve the agent from all responsibility on the
contract, when we would otherwise have been liable for such kind of act. So an infant is not liable
on his contracts; but if, after coming of age, he ratifies the contract by an actual or express
declaration, he will be bound to perform it, as if it had been made after he attained full age. Hence
it can be conferred that the ratification must be voluntary, deliberate, and intelligent, and the party
must know that without it, he would not be bound to fulfil the obligation. But a confirmation or
ratification of a contract, may be implied from acts of the infant after he becomes of age; as by
enjoying or claiming a benefit under a contract be might have wholly rescinded and an infant
partner will be liable for the contracts of the firm, or at least such as were known to him, if he,
after becoming of age, confirm the contract of partnership by transacting business of the firm,
receiving profits, and the like. We can take example of ratification of Treaties.

4
https://www.eaa.org.hk/en-us/Information-Centre/Publications/Agency-Law/-3-Formation-of-agency
[10]

EFFECT OF RATIFYING UNAUTHORIZED ACT FORMING PART OF


TRANSACTION

SECTION 199:

Section 199 says that a person ratifying any unauthorized act done on his behalf ratifies the
whole of the transaction of which such act formed a part

RATIFICATION OF UNAUTHORIZED ACT CANNOT INJURE THIRD PERSON:

SECTION 200:

Section 200 of the Indian Contract Act says that an act done by one person on behalf of another,
without such other person’s authority, which, if done with authority would have the effect of
subjecting a third person to damages, or of terminating any right or interest of a third person,
cannot, by ratification, be made to have such effect.

CONDITIONS FOR VALID RATIFICATION


• Act must be done on behalf of another:
The first essential to the doctrine of ratification, with its necessary consequence of
relating back, is that the agent shall not be acting of himself, but shall be intending to
bind a named or ascertainable principal. The agent must have done the act on the behalf
of the supposed principal. And the motive with which the act done is immaterial.
• Person ratifying must have been in existence at the time of act:
It has been laid down that ratification, in order to be effective, can only be by an authority
that is in existence on the date the transaction was entered into and it should also be
competent to ratify.
• The thing must exist:
In order to recognize or ratify something it is necessary that thing must exist,That is the
contract, or some rights or obligations arising under it, must be subsisting on the date of
Ratification.
• Ratification must be with full knowledge of all facts:
In order to establish case of ratification it is essential that the party ratifying should be
conscious.
[11]

1. Act to be ratified must not be void or illegal. An act which is void or illegal
cannot be validated by any amount of ratifications
2. There must be relationship of principal and agent.
3. Ratification to be exercised within reasonable time.

Validity Of Consent In The Agreements Which Are Subject To Ratification


The English common law relating to the above topic report from the two Latin Maxims Qui Per
Alium Facit Per seiprom facere Videtur and Qui Facit per alium facit perse thereby meaning “ He
who does not act through another is deemed in law to do it himself” and ‘he who acts by another
acts by himself”. The law of agency is based upon the consent of one party that the other party the
agent shall act on his behalf and the other party consents to do so. At common law the word Agency
represents a body of general rules under which one person the agent has the power to change the
legal relation of another, the principal.” According to ANSON “ Although at common law as a
general rule A cannot by contract with B to confer rights or impose liabilities upon a third party,
yet A may or act on the behalf of B with B’S authority for the purpose of bringing B into legal
relations with a third party.So principal is bound by the act done by an agent or the contracts made
by made by him on behalf of the principal in the same manner, as if the acts had been done or the
contracts had been entered into by principal himself, in person. Therefore when a contract is
entered into through the medium of an agent the principal becomes liable towards the third party
whether he has given his consent before or not, it does not matter even when such contracts are
voidable in nature. Ordinarily, as the agent is only a connecting link, he is not liable personally
towards the third party. The power to ratify remains with the principal itself so consent given or
not to agent it hardly matters because obligation part comes to principal.
[12]

Validity Of Minor’s Contract And State Liability For The Act Of Their Officers
In Minor’s case

The contract act simply states that a person who is of the age of majority is competent to contract,
and thus, a minor’s is not competent to contract. In Mohori Bibee v. Dhurmodas Ghose Privy
Council made it clear that that contract or agreement done with Minor is void. 5

No Ratification of a minor’s agreement.

An agreement entered into by a minor is void ab initio. a minor can’t ratify an agreement on
attaining the age of majority validate the same.

One of the reason for the rule that a minor cannot ratify an agreement after attaining majority is
that when the agreement was entered into during the minority there was no ‘proper consideration’
and the ‘bad consideration’ is not enough for validating that agreement by its ratification. This will
be clear from the observation of SULAIMAN, C.J. of the Allahabad High Court:

“Under section 11 a minor is not competent to contract he is disqualified from contracting. He can,
therefore, neither make a valid proposal nor make a valid acceptance as defined in section-2, clause
(a) and (b). He cannot, therefore, for the purposes of this Act be strictly called a promisor within
the meaning of clause (c). Nor can, therefore, anything done by the promise be strictly called a
consideration at the desire of a promisor as contemplated by clause (d). It may, therefore, be urged
that an argument by a minor cannot be strictly as being for “consideration’

If the part of the benefit was received by a person during his minority and the other part after
attaining the age of majority, a promise by him after attaining majority to pay an amount in respect
of both the benefits is enforceable, as that constitutes a valid consideration for the promise. A
minor can’t even enter into a contract through guardian or any other agent because it is void
contract and the same is not capable of ratification by aminor, on his attaining majority. According
to Privy Council stated that “ A ratification in law is treated as equivalent to a previous authority,
and it follows that as a general rule, a person or body of persons, not competent to authorise an act
can’t give validity after ratifying it.

5
https://www.eaa.org.hk/en-us/Information-Centre/Publications/Agency-Law/-3-Formation-of-agency
[13]

State liability for the act officers


The matter has been discussed under sec.65. In Chatturbhuj Vithaldas Jasari v. Moreshwar
Parashram, the contention was raised that the contracts having not been expressed to be made by
the President as required by Article 299 of the Indian constitution were void, but it was ruled that
the contracts in question are not void simply because the state officers who made such contracts
could be sued upon them, and they could be by the Government.

Ratification after principal’s death


It is common practice that if an agent functioning under a written authority of the principal holds
himself out as such agent after after the death of the principal and if person competent to ratify his
action after the death of the principal ratify the same in manner known to law, then the agent should
be deemed to have acted within the limits of authority and that he validly holds himself out as
agent of the subsequent proprietors.
[14]

CASE LAWS

Keighley, Maxsted & Co. v. Durant.

In this case, Keighley, Maxsted & Co. instructed Roberts to buy wheat on joint account, i.e., for
them and himself, at a certain rate. Wheat was not available to Roberts at that rate, so he purchased
wheat at a slightly higher rate. It was purchased by Roberts on his own account only. Keighley,
Maxsted & Co. purported to ratify the agreement, but subsequently, when the price fell, refused to
take delivery of wheat . In an action by the seller for breach of contract against keighley, maxsted
& co., it was held that they could not be made liable because the act by Roberts not having been
on their behalf purported ratification by them was ineffective.

Kerner v. Baxter

The promoters of a company which had yet been formed entered into, a contract on behalf of the
company After the company was formed, it ratified the contract. Then the company went into
liquidation.

An action was brought against th promoters to make them liable on the contract. They tried to
avoid their liability by pleading that after the contract made by them had been ratified by the
company was not in existence at the time of doing pf the act, the purported ratification was a
nullity, and, therefore, the liability of promoters continued in spite of ratification.6

Savery v. King

A entered into a mortgage agreement on B’S behalf. The agreement was invalid. Without knowing
thus fact, B purported to ratify the transaction. It was held that since B was not knowing about the
invalidity of agreement, the purported ratification of the same by him, was of the act.

Risbourg v. Bruckner

the act of the agent which had been done without the principal's authority was ratified by the latter,
it was held that on ratification, a valid contract between the principal and the third person was

6
http://lawtimesjournal.in/ratification/
[15]

created from the date when the agent had done the act, and, therefore, the agent could not be made
personally Liable because the agent's position had become the same as in the case of a previously
authorized act.

The effect of ratification of a contract entered into by the agent without the principal's prior
authority is, that the contract is deemed to have been made when the agent made the agreement
rather than the date of ratification by the principal, of that agreement.

Badri Prasad v State of Madhya Pradesh

There was an sale of cut timber of forest on 24th December, 1956. A made the highest bid and his
bid was accepted by the Divisional forest Officer. The payment was to be made in 4 instalments,
and the first installment was paid immediately. Second, third and fourth instalments were to be
paid subsequently, and for this payment, B (the appellant) stood as surety. The auction sale was
ratified by the chief Conservator of Forests, and the sale deed was signed by him on 3rd may, 1957.
A week before the Chief Conservator of Forests had ratified the contract, a fire had broken out and
the goods purchased by A had been destroyed by fire.

The appellant, B, filed a suit for declaration that he was not liable to pay the 2nd, 3rd and 4th
instalments as a surety for A. His contention was that the date of making of the contract was, 3rd
May, 1957, when the contract was ratified, and since the goods had been destroyed a week before
that date, there could not be a contract regarding that subject-matter and, therefore, there was no
liability to pay any price for the same.

It was held that:

(i) The formal signature of the competent authority ratifying the deed of contract, though
made on 3rd May, 1957, the contract was deemed to have been made on 24th
December, 1956, i.e., the date of the auction sale.
(ii) At the time of auction, the goods were specific, in a deliverable state, and there was an
unconditional contract, and, therefore, according to Section 20 of the Sale of Goods
Act, the property in the goods had passed to A, when his highest bid was accepted in
the auction sale.
(iii) B was liable as surety to pay the remaining instalments guaranteed by him.
[16]

M/s. Chandur Forgings (P.) Ltd. V. M/s. Bhandari Interstate carriers

the respondent company, a registered partnership firm, by special Power of Attorney, signed by
only one partner of the firm, authorized its Regional Manager to file the suit for recovery of freight
and other charges from the appellant. Subsequent to the filing of the suit, another power deed
signed by all the partners of the firm was executed. In view of Section 196 read with Section 199
of the Contract Act, 1872, the Madras High Court held that the defect in the first power deed stood
rectified by the execution of another power deed and the respondent firm could not be held to be
non-suited.

Bolton Partners v. Lambert

It was held that in spite of the fact that A seeks to revoke the offer, B's principal cart ratii7 the
agreement entered into between A and B. in other words, stated in the above illustration, the
contract between A and principal is- deemed to be made on 1st January, and A cannot, therefore,
revoke his offer after that.

A offered to purchase some Sugar Works belonging to a company. The company's managing
director, purporting to act on behalf of the company, but within any authority, accepted this offer.
Before the company had ratified the acceptance made by the managing director, A withdrew his
offer. The company still ratified the agreement. It was held that ratification related back to the
making of the agreement between A and the company's agent, A could not withdraw his offer, and
he was bound by the ratification.

The position would be different if the agent purports to make the contract 'subject to ratification'
by the principal, or the other contracting party knows about the limitation of the agent's authority.
In such a case, the date of the making of the contract is the date ratification, and there can possibly
be revocation of the offer before ratification.

Watson v. Davies

A offered to sell his property to the Bo of management of a charity for £ 6,500. A deputation
consisting of the Chairman and 12 other members of the Board, having been so Authorized, viewed
the property and interviewed A. They purported to accept A's otter 'subject to formal meeting' of
[17]

the Board. A meeting of the Board was -fixed "to receive the report and the recommendations of
the deputation." Before the report of the deputation was considered by the Board, A informed the
secretary of the Board cancelling all the negotiations. The meeting overlooked the revocation of
offer by A, and passed resolutions ratifying the deputation's acceptance of A's offer to sell his
property for £ 6,500, An action was then brought against A for specific performance.

It was held that acceptance of offer by the deputation was only subject to ratification by the Board,
and in such a case, there arises no contractual relation until ratification by the principal, and,
therefore, A was free to withdraw his offer at any time before ratification. As such, S could not be
made liable.7

7
Contracts – II by R.K Bangia
[18]

CONCLUSION

In India, the agent and principle share a relationship that is contractual in nature, and therefore it
is governed by the terms and conditions of the contract between them. Chapter X of the Indian
Contract Act, 1872 provides the basic structure of rules and regulations that basically govern the
performance and formation of any type of contract including the agency contract.

Agent and principal are defined under Section 182 of the Indian Contract Act, 1872. According
to the section “an agent is a person employed to do any act for another or to represent another in
dealings with third persons. The person for whom such act is done, or who is so represented, is
called the principal”.

Different types of commercial agents have been identified under Indian law like brokers,
auctioneers, del credere agents, persons entrusted with money for obtaining sales and insurance
agents.

The matter has been discussed under sec.65. In Chatturbhuj Vithaldas Jasari v. Moreshwar
Parashram, the contention was raised that the contracts having not been expressed to be made by
the President as required by Article 299 of the Indian constitution were void, but it was ruled that
the contracts in question are not void simply because the state officers who made such contracts
could be sued upon them, and they could be by the Government.
[19]

BIBLIOGRAPHY

BOOKS

• Contracts-II by R.K Bangia

STATUE

• Indian Contracts act, 1872

WEBSITES

• www.lawjournal.com
• www.indiankanoon.com
• WWW.SHODHGANGA.COM
• WWW.LAWYERSCLUB.COM
• WWW.LAWOCTOPUS.COM
• WWW.BARANDBENCH.COM
• WWW.WCD.NIC.IN