TAMIL NADU NATIONAL LAW UNIVERSITY, THIRUCHIRAPALLI

B. Com LLB (Hons) – III Semester

Academic year 2021 – 2022

Subject – Law of Contracts II

Understanding Lien and its types

Course Faculty Submitted By

Shanthi Samandha K MUKILAN P

Assistant Professor of Law (BCO200027)

TNNLU TNNLU
DECLARATION

I MUKILAN P, Register Number (BCO200027) , hereby declare that

this Research Paper / Research Project work entitled Understanding
Lien and its types has been originally carried out by me under the
guidance and supervision of Shanthi Samandha K, Assistant
Professor of Law, Tamil Nadu National Law University,
Tiruchirappalli – 620027. This work has not been submitted either in
whole or in part of any Degree / Diploma at any University.

Place: Tiruchirappalli

Date: (28/10/2021)

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 ACKNOWLEDGMENT

I would like to express my special thanks of gratitude to my teacher Shanthi

Samandha K, Assistant Professor of Law, as well as our Vice Chancellor Prof.
(Dr) V.S. Elizabeth who gave me the golden opportunity to do this wonderful
project on the topic “Understanding Lien and its types”, which also helped me
in doing a lot of Research and I came to know about so many new things I am
really thankful to them. Secondly, I would also like to thank my parents and
friends who helped me a lot in finalizing this project within the limited time
frame.

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Contents

Chapter 1 ................................................................................................................................................. 6
1.1 Introduction .................................................................................................................................. 6
1.2 Statement of problem................................................................................................................... 6
1.3 Research objectives ...................................................................................................................... 6
1.4 Research questions ....................................................................................................................... 6
1.5 Review of literature ...................................................................................................................... 6
Chapter 2 ................................................................................................................................................. 7
2.1 What Is Lien? ................................................................................................................................. 7
2.2 Types of Lien ................................................................................................................................. 7
2.2.1 Particular Lien (Sec 170 of Indian Contract Act 1872) ......................................................... 8
2.2.2 General Lien (Sec 171 of Indian Contract Act 1872) ............................................................ 8
2.3 Some More Types of Lien Are Listed Here .................................................................................... 8
2.3.1 Banker’s Lien ......................................................................................................................... 9
2.3.2 Negative Lien ......................................................................................................................... 9
2.3.3 Equitable Lien ........................................................................................................................ 9
2.3.4 Maritime Lien ...................................................................................................................... 10
2.4 Rights Obtained By the Lien ........................................................................................................ 10
2.4.1 Extent of the Right of Lien .................................................................................................. 10
2.4.2 Right of Lien of Third Parties .............................................................................................. 11
2.4.3 Right to Recover Expenses Survives Lien ........................................................................... 11
2.4.4 No Right of Lien .................................................................................................................. 11
Chapter 3 ............................................................................................................................................... 12
3.1 Importance of Lien ...................................................................................................................... 12
3.1.1 Protects the Buyer ................................................................................................................ 12
3.1.2 It allows the seller or an agent to recover the amount .......................................................... 12
3.1.3 Importance of Lien when buying a business ........................................................................ 12
3.1.4 Recovering the necessary and extra orbit expenses ............................................................. 13
3.2 The Impact of Liens ..................................................................................................................... 13
Chapter 4 ............................................................................................................................................... 13
4.1 Case Laws and Illustrations ......................................................................................................... 13

4
 4.1.1 State Bank of India v. Javed Akhtar Hussain, AIR 1993 Bom 87 ....................................... 14
4.1.2 Union Bank of India vs K.V. Venugopalan and Ors. AIR 1990 Ker 223. ........................... 14
4.2.3 Jain Mills and Electrical Stores v. State of Orissa, 1990 SCC OnLine Ori 74 .................... 15
Chapter 5 ............................................................................................................................................... 16
Conclusion ......................................................................................................................................... 16
Bibliography ...................................................................................................................................... 17

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Chapter 1
1.1 Introduction

A lien is the legal right to keep lawful possession of another person's property until the owner
meets a legal obligation to the person holding the property, such as paying legal costs for
work done on it. A common lien is a mortgage.

In its broadest sense, this phrase refers to any situation in which real or personal property is
used to fulfill an obligation or responsibility. In a more limited sense, it is described as the
right to retain another's property while a claim is resolved. Lien rights are usually created by
operation of law, but they can also be created by express contract in specific instances.

"Lien is in its fundamental meaning of right in one man to hold that which is in his
possession belonging to another until certain demands of the person in possession are met,"
according to Halsbury's law of England.

1.2 Statement of problem

In this study is we are going to study about what are lien and its importance. And also the
judicial interpretation to Lien and Section 171 of Indian contract act.

1.3 Research objectives

• To find the significance of Lien as a right of bailee?

• To know how many types of lien under Indian Contract act?

1.4 Research questions

• What is the significance of Lien as a right of bailee?

• What are the types of lien under Indian Contract act?
• What is the judicial interpretation to Lien and Section 171 of Indian contract act?

1.5 Review of literature

6
 1. Avtar Singh. Textbook on Law of Contract and Specific Relief. 7th ed., Eastern Book
Company, 2018.

In this book the author clearly speaks about the right of Lien and the types of Lien. He also
stated the types of lien covered by the Indian contract act.

2. Rai, Diva. “Critical Analysis of the Importance of Lien and Its Kinds.” IPleaders, 13
July 2020, https://blog.ipleaders.in/critical-analysis-of-the-importance-of-lien-and-its-
kinds/.

In this blog the writer broadly speaks about the importance of Lien, types of lien, and lien of
a finder of goods. And also cited some case laws and some sections of the act.

Chapter 2

2.1 What Is Lien?

A lien is a claim or legal right against assets used as collateral to repay a debt. A creditor or a
judicial judgment could place a lien on your property. A lien is used to secure an underlying
obligation, such as debt repayment. The creditor may be entitled to seize the asset that is the
subject of the lien if the underlying obligation is not met. Liens are used to secure assets in a
variety of ways.1

If the bailee's legal charges aren't paid, he has the right to keep the goods. The right of lien is
the legal right to keep any property until all costs owed on the property are paid. The
Supreme Court ruled that a lien is primarily a legal right, not a contractual right. There are
two types of liens: 2

(1) Particular lien (Sec 170 of Indian Contract Act 1872), and

(2) General lien (Sec 171 of Indian Contract Act 1872).

2.2 Types of Lien

1 DR. Avatar Singh, in Textbook on Law of Contract and Specific Relief 1729–1737 (7 ed. 2019).
2 DR. Avatar Singh, in Textbook on Law of Contract and Specific Relief 1729–1737 (7 ed. 2019).

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2.2.1 Particular Lien (Sec 170 of Indian Contract Act 1872)

As a general rule, a particular lien A bailee has just a particular lien, which means he or she
has the right to keep only the property for which the charge is due.

Section 170 of Indian Contract Act 1872 is as follows:

170. Bailee’s particular lien. — Where the bailee has, in accordance with the purpose of the
bailment, rendered any service involving the exercise of labour or skill in respect of the goods
bailed, he has, in the absence of a contract to the contrary, a right to retain such goods until he
receives due remuneration for the services he has rendered in respect of them.3

2.2.2 General Lien (Sec 171 of Indian Contract Act 1872)

The power to hold commodities bailed as security for a general balance of account, as defined
in Section 171 is known as a "general lien." Whatever goods bailed to him for any amount
owed to him, whether in respect of those goods or any other things, are subject to a general
lien, which allows the bailee to keep them. Where, for example, is a quantity of imported
goods? Meat was stored with a warehouse-keeper, who, due to a general term of the trade,
had a general lien, and it was decided that he might hold the meat to pay for other items owed
to him.

Section 171 of Indian Contract Act 1872 is as follows:

171. General lien of bankers, factors, wharfingers, attorneys, and policy-brokers. — Bankers,
factors, wharfingers, attorneys of a High Court and policy-brokers may, in the absence of a
contract to the contrary, retain as a security for a general balance of account, any goods bailed
to them; but no other persons have a right to retain, as a security for such balance, goods
bailed to them, unless there is an express contract to that effect.4

2.3 Some More Types of Lien Are Listed Here

3 Diva Rai -, Critical analysis of the importance of Lien and its kinds iPleaders (2020), https://blog.ipleaders.in/critical-analysis-of-the-
importance-of-lien-and-its-kinds/#Importance_of_Lien
4 Diva Rai -, Critical analysis of the importance of Lien and its kinds iPleaders (2020), https://blog.ipleaders.in/critical-analysis-of-the-
importance-of-lien-and-its-kinds/#Importance_of_Lien

8
2.3.1 Banker’s Lien

The banker's lien is an implicit promise, and if the property comes into his or her control in
the usual course of business, the banker has the right to sell it after giving sufficient notice.
According to a part of contract law, if a contract is breached, a banker's lien can be employed.

• The banker is in charge of the property.

• The banker's money instruments or products are not used for any purpose that is
incompatible with the lien.
• As a banker, I legally gained custody of the instruments.
• There is no tacit or explicit agreement to the lien's detriment.

The banker only gains a lien over pledged commodities in order to recover his debts, and he
is obligated to sell such goods in order to recoup his losses. Securities deposited with a
banker for a specified purpose that is incompatible with the lien will not be covered by the
banker's general lien.5

2.3.2 Negative Lien

A borrower may be requested to sign a letter declaring that the assets are free of all charges
and encumbrances when a bank grants an advance. The borrower also promises that the
assets included in the declaration will not be encumbered or sold until the bank has given
written approval. This project is called Negative Lien. The agreement is usually written in the
form of a contract. The banker is unable to retrieve debts disguised in such assets. The
banker's interests, on the other hand, are safeguarded to some extent.6

2.3.3 Equitable Lien

An equitable lien is an equitable right granted by law to a charge on another's immovable or

moveable property until certain particular demands are satisfied. The operation of law creates
an equitable lien. The following are examples of equitable liens.

• The sale revenues of the pledged items will be placed in the loan account if the lender
releases the pledged goods to the borrower using a trust receipt.

5 Right to Lien and bailment: Judicial interpretation, Legal Service India - Law, Lawyers and Legal
Resources, https://www.legalserviceindia.com/legal/article-1891-right-to-lien-and-bailment-judicial-interpretation.html.
6 Right of lien - conditions & types, IndiaFilings (2019), https://www.indiafilings.com/learn/right-of-lien/

9
 • Until the purchase money is paid in full or in part, an unpaid vendor of immovable
property has an equitable lien on the property for the entire or part of the purchase
money.
• On dissolution, a partner who pays partnership debts gets an equitable lien on the
partnership's assets.7

2.3.4 Maritime Lien

A marine lien is a legal right to bind a ship, its contents, machinery, cargo, and freight for the
payment of a maritime law claim. 8

2.4 Rights Obtained By the Lien

2.4.1 Extent of the Right of Lien

The bailee's lien extends to services involving the application of labour or skill that he
supplies in connection with the bailed goods. The lien must be limited to the bailer's labour or
skill used to the bailed goods; it cannot be applied to any other form of service. Such labour
and skill must have been used, first, in accordance with the bailment's purpose, second, to
improve the commodities bailed, and third, the lien only applies to those items over which the
bailee has spent his labour and expense, not to other products.

The worker just has the right to keep the products bailed in his custody, and he is not allowed
to do any self-help remedies, such as removing any engine components. Unless the bailee has
been specifically granted the power to sell the goods and recover the dues by legislation, the
right of lien does not entitle the bailee to sell the goods and recover the dues. The fact that
products are provided to a person under an entire contract at various periods does not impact
his entitlement to a lien on all items dealt with under that contract.

As a result, if jute was given to a pressing firm from time to time to be bailed, although the
total number of contracts was less than one, the lien was held to apply to all such items.
Despite the fact that section 170 gives the bailee the right to keep items until he is paid for the
services he has provided in relation to them, there is nothing in the section that allows him to

7 Right of lien - conditions & types, IndiaFilings (2019), https://www.indiafilings.com/learn/right-of-lien/

8 Right of lien - conditions & types, IndiaFilings (2019), https://www.indiafilings.com/learn/right-of-lien/

10
sell the goods and recoup his losses. As a result, a person entrusted with grazing cattle is
unable to sell them in order to recoup grazing expenses owed.9

2.4.2 Right of Lien of Third Parties

When a bailee of goods delivers them to a third party for work and the circumstances indicate
that he had the owner's permission to do so, such as when he expressly agrees with his bailer
to keep the goods bailed from injury, and this term in the agreement necessarily implies that
the goods will be repaired by a third party, or a trade custom in that regard can be proven, the
third party who performs the work on the bailee's order has an effective lien on the goods. 10

2.4.3 Right to Recover Expenses Survives Lien

Even if the bailee loses his right of lien when he loses ownership of the goods, he retains the
right to collect the costs he expended to protect the commodities from degradation not
covered by the bailment contract.

2.4.4 No Right of Lien

If the bailee has held the object bailed beyond the stipulated term, or a reasonable time, for
the completion of the job and has failed to do so, there is no claim of lien. An accountant who
fails to provide the bailer with enough information of the services performed is unable to
execute a lien.

When an express contract exists to execute specific work for a certain quantity of money, the
contract must be completed in its full before the pay may be claimed; there is no opportunity
for a quantum merit claim for portion of the job completed. When an organ is sent for repairs
for a specified cost, the person who receives it is not allowed to keep it as security for a sum
of money for part of the work done if he refuses to fix it for whatever reason. There is no
other "appropriate compensation" than the sums specifically negotiated for while the
particular contract is in effect..11

9 Right to Lien and bailment: Judicial interpretation, Legal Service India - Law, Lawyers and Legal
Resources, https://www.legalserviceindia.com/legal/article-1891-right-to-lien-and-bailment-judicial-interpretation.html.

10 Right to Lien and bailment: Judicial interpretation, Legal Service India - Law, Lawyers and Legal
Resources, https://www.legalserviceindia.com/legal/article-1891-right-to-lien-and-bailment-judicial-interpretation.html.

11 Right to Lien and bailment: Judicial interpretation, Legal Service India - Law, Lawyers and Legal
Resources, https://www.legalserviceindia.com/legal/article-1891-right-to-lien-and-bailment-judicial-interpretation.html

11
Chapter 3

3.1 Importance of Lien

A lien is the right to maintain possession of another person's property until the other person
satisfies the person in possession's demands. Lien had the cure, and it was recognized as a
legal privilege. Because it was imposed by the common law courts, the lien contract was built
on the notion that it was not between the parties and that each party had rights. As a result,
the importance of lien may be appreciated.12

3.1.1 Protects the Buyer

The establishment of a lien is critical because it protects the lenders' rights in the event of
non-payment of dues. As a result, loans with collateral are less risky for the lender and might
result in reduced interest rates for the borrowers. When a person buys a car, for example, it's
critical that he examines all of the liens that have been placed on it. Furthermore, if there is an
outstanding debt on that particular vehicle, the buyer runs the danger of the lender seizing the
vehicle.

3.1.2 It allows the seller or an agent to recover the amount

A lien is the right to maintain possession of another person's property until the other person
satisfies the person in possession's demands. The demand might range from the fulfillment of
a duty to the payment of a debt. The agent can collect money by selling the security if the
principal or buyer fails to pay the amount owed to the agency or a sailor, and this right was
formed as a consequence of the lien.13

3.1.3 Importance of Lien when buying a business

When buying a firm, it's a good idea to double-check that the assets aren't encumbered by
liens, as this could stifle the company's growth and advancement. As a result, when
negotiating a business deal, one can truly defend themselves.

12 Diva Rai -, Critical analysis of the importance of Lien and its kinds iPleaders (2020), https://blog.ipleaders.in/critical-analysis-of-the-
importance-of-lien-and-its-kinds/#Importance_of_Lien
13 Diva Rai -, Critical analysis of the importance of Lien and its kinds iPleaders (2020), https://blog.ipleaders.in/critical-analysis-of-the-
importance-of-lien-and-its-kinds/#Importance_of_Lien

12
3.1.4 Recovering the necessary and extra orbit expenses

When it comes to retrieving the essential and additional orbit expenses that the seller or agent
reserves, the importance of lien comes into play. The clause of the agent's lien was examined
by the High Court in the matter of Gokaldas v. Thakurdas. The agency was a firm that
received commissions from agents who delivered items to the principals who were under
their control. Even the principal contributed funds to the purchase of the products. The agent,
on the other hand, spent money from his own pocket at other times.

As a result, the agent auctioned the principal's possessions to recoup his debt. The court
pointed out that the agent selling the principal's goods may not be justified since he lacked
control over the principal's goods. However, the agent paid for part of the items out of his
own pocket, and as a tacit pledgee, he has the right to recoup as much of his investment as
possible by selling the commodities in his custody.14

3.2 The Impact of Liens

In most cases, the lien holder's rights are limited to a minimal right of retainer. When a
creditor makes advances on a factor's products, he is usually given the right to sell. A court of
equity would decree it in some circumstances when the lien would not grant authority to sell.
And admiralty courts will order a sale to satisfy maritime liens.

In most cases, judgments obtained in courts of record are liens on the real estate of the
defendants or parties against whom they were issued. There are two types of liens: legal and
equitable. The former can be enforced in a court of law, whereas the latter can only be
enforced in a court of equity. An equitable lien is a lien that a seller of real estate has on the
property sold for the purchase money that has not been paid.15

Chapter 4

4.1 Case Laws and Illustrations

14 Diva Rai -, Critical analysis of the importance of Lien and its kinds iPleaders (2020), https://blog.ipleaders.in/critical-analysis-of-the-
importance-of-lien-and-its-kinds/#Importance_of_Lien
15 The legal definition of Lien: Everything you need to know, UpCounsel (2020), https://www.upcounsel.com/legal-def-lien#the-impact-of-
liens.

13
4.1.1 State Bank of India v. Javed Akhtar Hussain, AIR 1993 Bom 87

The court found that the bank's behavior in holding a lien on the TDR and RD accounts was
unilateral and high-handed, and that it was not suitable of the State Bank of India's powers.
The court cited the case of Union Bank of India vs. K.V. Venugopalan, in which the court
determined that the money in the bank's fixed deposit account is purely a loan to the bank. In
the case of the FD, the banker is a debtor. As a result, the depositor would no longer be the
owner of the money in the fixed deposit.

The money becomes bank money, allowing the bank to do anything it wants with the caveat
that the loan must be repaid at maturity. The bank, as a debtor in respect of the money in FD,
had no authority to pass the doctrine of banker's lien and the money in Fixed Deposit into
service, according to the same judgment.16

4.1.2 Union Bank of India vs K.V. Venugopalan and Ors. AIR 1990 Ker 223.

Here in this case Union Bank of India is the petitioner

The facts necessary to resolve the subject under discussion are contained within a small
scope. In O.S. 522/81, the decree-holder is the first respondent, while respondents 2 and 3 are
the judgment-debtors. Before judgment, the first respondent had acquired an attachment of
the judgment-debtors' truck. The attachment, on the other hand, was based on one E. V. John,
the judgment-debtors' brother, providing the court with a fixed deposit receipt for Rs. 6,500/-
issued by the petitioner-bank as security.

In order to carry out the ruling, the court designated the bank as a garnishee and ordered the
bank to deposit the sum and interest on the fixed deposit in court. This judgment, which
directs the bank to deposit the sum on behalf of the decree-holder, was issued after the bank's
claim that it had a 'lien' over the amount in fixed deposit was rejected. The bank filed E.A.
781/87 requesting review of the ruling since it was passed without addressing the bank's
aforesaid claim, according to the bank.

The bank claims in its petition that it has the right to keep this money in order to use its
general power of 'lien' and allocate it to sums owed to it under the loan account.

The court below by the order under challenge has dismissed the review application.

16 State Bank of India v. Javed Akhtar Hussain, 1992 SCC OnLine Bom 290

14
Certain truths are acknowledged, and they are as follows: On November 14, 1981, E. V. John
made a fixed deposit. He had taken out an agricultural loan the same day. The fixed deposit
receipt was presented to the court as security on November 16, 1981, and the order attaching
the lorry was dismissed when the court accepted the claimed security.

The petitioner's learned counsel believes that, under these circumstances, the bank can rely on
its 'general lien' to shield itself against losses incurred as a result of the agricultural loan
transaction with E.V. John. A reference in the connection to Section 171 of the Contract Act
is profitable, the counsel submits. On the other hand, it was argued on behalf of the decree-
holder that there was no amount legally due from E. V. John to the bank at the time the fixed
deposit receipt was given as security to the court for the lifting of the attachment, and thus,
even if the bank can exercise the 'banker's lien,' it can only do so subject to the charge created
in favor of the court.

In view of the explanation above, the executing court's order to deposit Rs. 8,812/- mentioned
in the petition E.A.878/87 treating the bank as a garnishee is unchallengeable. There is no
prohibitory order from the court regarding the balance amount in the fixed deposit, thus it is
up to the bank to decide whether it may be used to the sums due from E. V. John to the bank
under the agricultural loan account.

The court accordingly is dismissed the case. But in the circumstances no order as to costs. 17

4.2.3 Jain Mills and Electrical Stores v. State of Orissa, 1990 SCC OnLine Ori 74

The plaintiffs prefer this appeal against the judgment dated 28-3-1979 and decree dated 10-4-
1979 passed by the Subordinate Judge, Bhubaneswar, in OS No 41 of 1975 III, disallowing
the plaintiffs claim to the extent of Rs 47,792.04, while decreeing the suit in part only for a
sum of Rs 24,099 58.

The plaintiff's case may be briefly stated as follows:

The plaintiffs are the partners of Jain Mills and Electrical Stores, a registered partnership that
trades in electrical goods and distributes electrical equipment, appliances, and materials to
government and semi-government departments as well as the general public. On behalf of the
State of Orissa, Defendant No. 2 is the Executive Engineer, Lift Irrigation (Electrical)

17 Union Bank of India v. K.V. Venugopalan, 1990 SCC OnLine Ker 12

15
(defendant No. 1). On 5-2-1973, tenders for the provision of electrical items were issued, and
the plaintiffs' business responded by submitting bids.

The defendants received the plaint schedule goods, but despite repeated demands for payment
from the plaintiffs, the defendants did not pay the price thereof. So, ultimately, the plaintiffs
issued letters to the defendants on 23-8-1973 and also on 18-9-1973 demanding that the
defendants return the A schedule goods that the Lift Irrigation Department was wrongfully
withholding without paying the price thereof, and the defendant No 2 extended the stipulated
period of supply of the goods that the plaintiffs had not supplied until 7-4 1973 by his letter
dated 27-9-1973.

On October 16, 1974, the plaintiffs issued a Section 80 CPC notice. The defendants were
served with the notice, but they did not return the plaint schedule goods or pay the sum
specified in the notice. As a result, the plaintiffs filed the Sult, requesting the return of the
plaint a schedule goods and, alternatively, demanding payment of Rs. 66,735.62 towards the
market value of the plaint 'A' schedule goods, plus interest at 12% per annum, beginning on
October 16, 1974, the date of the S. 80, C.P.C. notice. As a result, the action was brought for
Rs. 72,891.62 p. as calculated in plaint schedule B.

As a consequence of the judges' judgments on the various arguments stated in the appeal, the
appeal is determined to be without merit, and it is dismissed on challenge, but without costs
under the circumstances of the case. 18

Chapter 5

Conclusion

A lien is one of the rights a person has to hold custody of goods owned by another person
until the assertion of the person in control is met. Under the Indian Contract Act of 1872, the
Bailee is free to use or exercise the Right of Lien under a Contract of Bailment.

The foundation of the Right of Lien is described by the Honorable Supreme Court as "a right
of a person to hold possession of commodities until the rights of the possessor are honoured."
Lien has the potential to be a tremendous asset. A bailee who is responsible for many

18 Jain Mills and Electrical Stores v. State of Orissa, 1990 SCC OnLine Ori 74

16
hundred TEUs (twenty-foot equivalent units) every day, particularly if none of the containers
are in default.

General Lien, in my opinion, is a far more effective mechanism for securing outstanding
debt. However, it has its own limitations and concerns, notably in terms of possible
responsibility. Basically, if a general contractor wants to execute a lien, he or she must
commit to take the case through to a successful finish, even if it is tough in terms of
commercial talks.

Liens are vulnerable to a range of threats, however despite these threats, liens continue to
give important assistance and support to operators. A well-drafted Lien clause might be a
huge aid and support to the operators. The range of debt and liabilities is substantially greater
than typical terminal services in Lien's worldwide terminals, the group and subsidiary of a
specific business, and in terms of debt and liabilities.

Bibliography

1. Distinction/difference between general Lien and particular Lien SRD Law

Notes, https://www.srdlawnotes.com/2017/06/distinction-difference-between-
general_4.html.
2. Diva Rai -, Critical analysis of the importance of Lien and its
kinds iPleaders (2020), https://blog.ipleaders.in/critical-analysis-of-the-importance-of-
lien-and-its-kinds/#Importance_of_Lien.
3. DR. Avatar Singh, in Textbook on Law of Contract and Specific Relief 1729–1737 (7
ed. 2019).
4. The legal definition of Lien: Everything you need to
know, UpCounsel (2020), https://www.upcounsel.com/legal-def-lien#the-impact-of-
liens.
5. Lien, Corporate Finance
Institute (2020), https://corporatefinanceinstitute.com/resources/knowledge/other/lien/
.
6. Pollock & Mulla, The Indian Contract Act 1872 (2018).
7. Right of lien - conditions &
types, IndiaFilings (2019), https://www.indiafilings.com/learn/right-of-lien/.

17
 8. Right to Lien and bailment: Judicial interpretation, Legal Service India - Law,
Lawyers and Legal Resources, https://www.legalserviceindia.com/legal/article-1891-
right-to-lien-and-bailment-judicial-interpretation.html.
9. State Bank of India v. Javed Akhtar Hussain, 1992 SCC OnLine Bom 290
10. Union Bank of India v. K.V. Venugopalan, 1990 SCC OnLine Ker 12
11. Jain Mills and Electrical Stores v. State of Orissa, 1990 SCC OnLine Ori 74

18