UG21-72 Corporate Law Final Draft

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UNDERSTANDING THE PROCESS OF VALUATION OF

SUITS

Subject: 6.1 Code of Civil Procedure and Law of limitation


(Project Final Draft)

Submitted by
MUSKAN
UID No: UG21-72
BA.LL.B.(Hons) Five-Year Integrated Degree Course
Academic Year:2022-23
Year: III Semester: VI

Submitted to

Prof. Sanya Agarwal


Assistant Professor of Law

March 2024

MAHARASHTRA NATIONAL LAW UNIVERSITY, NAGPUR


Table of Contents
Table of Cases.....................................................................................................................I

Table of Statutes.................................................................................................................I

INTRODUCTION.............................................................................................................1

RESEARCH METHODOLOGY.....................................................................................2

RESEARCH OBJECTIVES.............................................................................................2

RESEARCH QUESTIONS...............................................................................................3

Scope and Limitation of the process of valuation of suit................................................3

Relevant provisions in consonance with valuation of suits for determination of

court fees........................................................................................................................5

Relevant provision in consonance with suit value for determination of jurisdiction7

Ascertaining the process of valuation of suits through relevant judicial

pronouncements.................................................................................................................9

Conclusion........................................................................................................................11

Bibliography....................................................................................................................12
Table of Cases
S.no Name of the Parties Citation
1. State of Punjab v. Dev Brat Sharma & Ors. 1966 Supp SCR 128
2. Chief Inspector of Stamps v. Indu Prabha (1998) 9 SCC 157
Vachaspati
3. Allam Venkateswara Reddy v. Golla AIR 1975 AP 122
Venkatanarayana
4. Smt. Narbada v. Smt. Aashi AIR 1987 Raj 162
5. Gurudevdatta VKSSS Maryadit v. State of (2001) 4 SCC 534
Maharashtra
6. Padma Sundara Rao (Dead) v. State of Tamil (2002) 3 SCC 533
Nadu
7. R. Rangiah v. Thimma Setty (1963) 1 Mys LJ 67
8. Arunachalathammal v. Sudalaimuthu Pillai (1968) 83 MLW 789
9. Pachayammal v. Dwaraswamy Pillai (2006) 3 KLT 527
10. Balireddi v. Khatipulal Sab AIR 1935 Mad 863
11. P.K. Vasudeva Rao v. Hari Menon AIR 1982 Ker 35
12. Venkata Narasimha Raju v. Chandrayya AIR 1927 Mad 825
13. Sathappa Chettiar v. Ramanathan Chettiar 1958 SCR 1024

14. Meenakshisundaram Chettiar v. AIR 1979 SC 989


Venkattachalam Chettiar
15. Kanai Lal Sur v. Paramnidhi Sadhukhan 1958 SCR 360
16. Nemi Chand v. Edward Mills Co. Ltd. 1953 SCR 197: AIR
1953 SC 281
17. Gopalakrishna Pillai v. Meenakshi Ayal 1966 Supp SCR 128
18. Shamsher Singh v. Rajinder Prashad (1973) 2 SCC 524
19. Gopal Chandra Jena v. Laxmi Narayan Bijo AIR 1990 Ori 98
Maura Alava

Table of Statutes
Civil Procedure Code, 1908
Suit Valuation Act, 1887
Court Fees Act, 1870
INTRODUCTION
The suit's appraisal is a crucial step in the legal process in civil actions. It pertains
to the financial evaluation of the subject matter in dispute in terms of jurisdiction,
court costs, and the overall administration of justice. Specific conditions for the
valuation of claims are provided by several sections of the Code of Civil Procedure
(CPC), 1908, which governs the procedural aspects of civil litigation. The
usefulness of a suit becomes apparent as a vital link connecting jurisdiction, money
considerations1, and the general fabric of justice in the complex tapestry of civil
litigation. This process comprises putting a monetary value on the main point of
contention.

The suit's appraisal is important for a number of reasons. One of the primary
objectives is deciding which court to file a lawsuit in. Several courts have
jurisdiction over cases that fit within specific financial parameters. For example, a
lawsuit with a lower value could be brought in a lower court, whereas a case with a
larger value could be filed in a higher court. A precise appraisal ensures that the
case will be heard in the appropriate court, promoting an efficient and speedy legal
procedure.2 Precise case valuation functions as a cornerstone in the intricate web of
civil litigation, where justice is disbursed via a methodical legal procedure,
coordinating a harmonious synchronization of the case's attributes.3

The CPC4 works to prevent "forum shopping," which is the practice of selecting a
court or jurisdiction in an effort to increase the possibility of a favourable outcome.
Through the establishment of financial thresholds for different courts, the CPC
discourages litigants from exploiting the system.5 Forum shopping is the deliberate
selection of a court or jurisdiction to maximize the chances of a favourable
1
Chiapello, Eve. “Financialisation of Valuation.” Human Studies 38, no. 1 (2015): 13–35.
2
Das, J.K. “RETHINKING THEORETICAL FOUNDATIONS OF THE CODE OF CIVIL
PROCEDURE: PROSPECT AND RETROSPECT.” Journal of the Indian Law Institute 53, no. 1
(2011): 1–31.
3
“The Code of Civil Procedure in India.” Journal of the Society of Comparative Legislation 8, no.
2 (1907): 235–38.
4
Gajaseni, “The civil procedure code”, Sutra Paisal Law Media, 2002, pg.235.
5
Ghosh, Priyabrata. “CIVIL JUSTICE SYSTEM: ITS DELAYS AND SOLUTIONS.” Journal of
the Indian Law Institute 41, no. 2 (1999): 264–71.

1
outcome, akin to a calculated move in chess. A lawsuit needs to be valued in order
to establish the financial jurisdiction of the court where it should be filed as well as
the amount of the court fee that must be paid. The methods for valuing a suit are
prescribed by the Suit Valuation Act 1887 and the Court Fees Act 1870,
respectively, in order to establish the jurisdiction of courts and the amount of court
fees that must be paid in a suit.6 While this is not always the case, in many
instances the two valuations are likely to be the same. 7 It is possible that a suit's
worth for jurisdictional purposes will differ from its value for court fee purposes.
The scope, limitations, and methodology of the aforementioned valuation are the
main subjects of this study endeavour.

RESEARCH METHODOLOGY

Doctrinal method of research has been utilised in order to approach the afore-
mentioned study. This study has gathered its content from various reports, articles,
journals and textbooks, thus following a source-based approach. The
aforementioned method is both descriptive and analytical and descriptive in nature.
An extensive literature review has been used to comprehensively explore the issues
in this project. The researcher has attempted to conduct a thorough and incisive
analysis by critically analysing all of the sources. Comprehensive study has also
drawn on the perspectives of scholars and researchers who have previously
addressed a related topic.

RESEARCH OBJECTIVES

 To evaluate the process of valuation of suit in consonance with the code of


civil procedure.

6
Tupper, Lewis. “The Indian Code of Civil Procedure.” Journal of the Society of Comparative
Legislation 9, no. 1 (1908): 69–78.
7
Dodson, Scott. “COMPARATIVE CONVERGENCES IN PLEADING STANDARDS.”
University of Pennsylvania Law Review 158, no. 2 (2010): 441–72.

2
 To collate the Suit Valuation Act 1887 with that of the Court Fees Act 1870
and to offer several suggestions and insights in order to improve the
effectiveness of the procedure of valuation of suits.
 To elucidate and ascertain the scope and limitation of the said process with
the help of relevant judicial pronouncements.

RESEARCH QUESTIONS

1. What are the purpose and object of the Suits Valuation Act of 1887 and the
Court-Fees Act of 1870, and is there any overlap between the two laws?
2. When and if the Court may postpone making a decision about an objection
regarding the suit's worth for the purposes of the Court-Fees Act, 1870 and
the Suits Valuation Act, 1887?
3. How do the Court-Fees Act, 1870 and the Suits Valuation Act, 1887
determine the value of a suit, and how much weight does the defendant's
plea or defence have in this process?
4. In the event that the court determines that a specific lawsuit is undervalued,
what steps should be taken and is the lawsuit subject to dismissal on this
basis alone?
5. Which charging sections and rules, along with its judicial pronouncements,
are pertinent for calculating the fees that must be paid for the various types
of suits?

Scope and Limitation of the process of valuation of suit

It is not possible to regard the Court-Fees Act of 1870 and the Suits Valuation Act
of 1887 as constituting a code or as pari materia with respect to their individual
clauses.8 To put it another way, you cannot read them aloud. The value of the suit
is determined under both Acts, which is the only similarity between both.
Therefore, the Court-Fees Act is a fiscal statute 9 that establishes guidelines for

8
Osborough, Nial. “Court Fees.” Irish Jurist (1966-) 9, no. 2 (1974): 318–19.

3
figuring out the suit's value for Court-Fees purposes. 10 Consequently, it can be said
that the assessment of a suit for jurisdictional purposes under the Suits Valuation
Act is different from its assessment for Court-Fees fiscal purposes under the Court-
Fees Act, 1870. While the value of the suit is calculated for fiscal purposes based
on specific legislative principles, under the Suits Valuation Act, 1887, the suit's
worth is contingent upon the subject matter's value.

Preliminary challenges to the plaint often centre on suit valuation, as stated by the
Advocates in their written submissions.11 The trial Court should not wait until the
case is over to decide whether or not a claim has been fairly valued; rather, the
Court, which must try the case, should make this determination right away because
it gets to the heart of the matter. Furthermore, the averments stated in the plaint
determine and dictate the suit's worth for jurisdictional and cost considerations,
without taking the defendant's pleas or defence into consideration. Put another
way, one need only consider the plaint and not the written declaration when
determining the case's worth.12 Furthermore, the jurisdiction and court fees are
initially determined by the plaintiff's projected valuation based on the allegations
made in his plaint.

If the Court determines after reviewing the plaint that the relief sought is
undervalued, it should issue a demand on the plaintiff to rectify the valuation
within a certain amount of time. Should he fail to do so, the plaint may be rejected
in accordance with Order VII, Rule 11 of the Civil Procedure Code. If further
proceedings in the matter are halted, the Court may record evidence from the
parties bearing on the issue and, as a result, decide the subject as soon as possible.
It is important to note that the Court-Fees Act, 1870, clearly states in section 10
that the claim would be dismissed if the plaintiff does not make good the
deficiency within the allotted time frame, despite the court's orders. 13 Before

9
MAXEINER, JAMES R. “Cost and Fee Allocation in Civil Procedure.” The American Journal of
Comparative Law 58 (2010): 195–221. http://www.jstor.org/stable/20744539.
10
Chief Inspector of Stamps v. Indu Prabha Vachaspati, (1998) 9 SCC 157.
11
Allam Venkateswara Reddy v. Golla Venkatanarayana, AIR 1975 AP 122.
12
Smt. Narbada v. Smt. Aashi, AIR 1987 Raj 162.
13
Gurudevdatta VKSSS Maryadit v. State of Maharashtra, (2001) 4 SCC 534.

4
concluding this introduction, it is important to clarify that the Court-Fees Act of
1870, like the Registration Act and the Indian Stamp Act of 1899, is a fiscal act
that needs to be properly read. It is therefore emphasized once more that the goal
of the current act is to protect the State's finances rather than to provide a claimant
with a technical legal weapon.14

Relevant provisions in consonance with valuation of suits for determination of


court fees

The Court-Fees Act, 1870's Section 1 addresses the Act's title, scope, and
beginning. As a pricing section, Section 3 specifies the fees that must be paid in
accordance with the Second Schedule of the Act for a number of particular
circumstances.15 The process for determining whether a charge is necessary or
appropriate and for making decisions regarding valuation-related issues is outlined
in Sections 5 and 12, respectively. The determination of valuation made in
accordance with these articles is final. Section 6 of Chapter 3 of the Court-Fees
deals with fees for documents filed, among other things, in Mofussil Courts or
public offices. The estimation of fees payable in certain proceedings is provided in
Section 716, which is a crucial requirement under the Act which is as follows-

“Section 7. Computation of fees payable in certain suits. -The amount of fee


payable under this Act in the suits next hereinafter mentioned shall be computed as
follows:-

(i) For money-In suits for money (including suits for damages or compensation, or
arrears of maintenance, of annuities, or of other sums payable periodically)-
according to the amount claimed;

14
Das, J.K. “RETHINKING THEORETICAL FOUNDATIONS OF THE CODE OF CIVIL
PROCEDURE: PROSPECT AND RETROSPECT.” Journal of the Indian Law Institute 53, no. 1
(2011): 1–31.
15
Padma Sundara Rao (Dead) v. State of Tamil Nadu, (2002) 3 SCC 533.
16
R. Rangiah v. Thimma Setty, (1963) 1 Mys LJ 67.

5
(ii) For maintenance and annuities. -In suits for maintenance and annuities or
other sums payable periodically-according to the value of the subject-matter of the
suit, and such value shall be deemed to be ten times the amount claimed to be
payable for one year;

(iii) For other movable property having a market value. -In suits for movable
property other than money, where the subject-matter has a market value according
to such value at the date of presenting the plaint;

(iv) In suits-

(a) For movable property of no market value. - For movable property where the
subject-matter has no market value as, for instance, in case of documents relating
to title,

(b) To enforce a right to share in joint family property. -To enforce the right to
share in any property on the ground that it is joint family property,

(c) For a declaratory decree and consequential relief. -To obtain a declaratory
decree or order, where consequential relief is prayed,

.........(f) for abatement of rent- according to the amount of the rent of the
immovable property to which the suit refers, payable for the year next before the
date of presenting the plaint."

Section 8 addresses the cost of filing a memorandum of appeal against a


compensation order pertaining to any Land Acquisition Act that is currently in
effect.17 When it is indicated that the suit has been undervalued, Section 9 gives the
Court the authority to look into the yearly net profits or market worth of any land,
house, or garden, as the case may be. 18 Since Section 10 is an addition to Section 1,
the two sections together offer a mechanism for determining the land and home
values that are the subject of the lawsuit in the event that the Court determines that
the values have been incorrectly evaluated to the prejudice of the Revenue.

17
Arunachalathammal v. Sudalaimuthu Pillai, (1968) 83 MLW 789.
18
Pachayammal v. Dwaraswamy Pillai, (2006) 3 KLT 527.

6
Additionally, it stipulates that in such a situation, the lawsuit will be put on hold
until the additional cost is paid and that if it is not paid within the allotted time, the
lawsuit will be dismissed.

Section 12 was ostensibly created for fiscal objectives, and it is emphasized once
more that its aim is not to provide a litigant with a technical legal weapon. It must
therefore be interpreted rigorously. This provision renders the first court's decision
regarding the suit's value as final between the parties and allows a court of appeal
to correct any error in this regard—but only if the first court's decision is made at
the expense of the Revenue. It is not applicable, however, when the question at
hand relates to the suit's class or category or the Court of First Instance's
jurisdiction.19 Put another way, an appeal lies against the decision regarding the
suit's class, but not against the decision regarding its valuation within that class.20

Relevant provision in consonance with suit value for determination of


jurisdiction

Sections 7(iv) of the Act and Section 8 of the Suits Valuation Act, 1887 must be
read in order to make this determination. The aforementioned section stipulates
that in cases where court fees are payable ad valorem under the Court-Fees Act,
1870, section 7, paragraphs V, VI, and IX, as well as paragraph X clause (d), the
value determined for the computation of court fees and the value for jurisdictional
purposes shall be the same.

Put another way, section 8 of the cases Valuation Act states that the value as
determined for the computation of court fees and the value for purposes of
jurisdiction shall be the same with regard to cases falling under section 7, sub-
section (iv) of the Act.21 It is reasonable to assume that the requirements of section

19
Balireddi v. Khatipulal Sab, AIR 1935 Mad 863.
20
P.K. Vasudeva Rao v. Hari Menon, AIR 1982 Ker 35.
21
Venkata Narasimha Raju v. Chandrayya, AIR 1927 Mad 825.

7
8 will have the effect of making the value for jurisdictional purposes dependent
upon the value as determined for the computation of court fees.

When a lawsuit falls under section 7(iv) of the Act, the plaintiff's claim assessment
determines how much the court will charge. The value for jurisdiction is
established if the plaintiff exercises his choice and evaluates his claim for the
purpose of court fees. In these kinds of situations, the value of jurisdiction and the
value of court fees must undoubtedly be equal; yet, the plaintiff's asserted value of
court fees is what matters most. The value for jurisdiction must be calculated based
on this value. As a result, the value of jurisdiction in the lawsuit is established by
the plaintiff's assessment of the relief requested for the purposes of court fees and
not vice-versa.22”

The plaintiff is free to estimate the reliefs sought in the plaint in a suit for
declaration with consequential relief under section 7(iv)(c) of the Court-Fees Act,
1870. As such, valuation must be generally accepted for the purposes of both
Court-fee and jurisdiction. The court can only review and amend the valuation in
situations where it becomes apparent from the facts and circumstances of the case
that it was arbitrary, unreasonable, and that the plaint had been demonstratively
undervalued.23

It is true that in an accounts suit, the precise amount owed by one party to the other
may only be determined upon examination of the accounts; an accurate claim value
cannot be provided at the outset of the suit. Thus, the plaintiff is free to choose his
own preliminary value.24 Generally, the plaintiff has the right to exercise his or her
value choices, but if the plaintiff arbitrarily selects a nonsensical sum, the plaintiff
has forfeited that privilege. The court has an obligation to reject such a value in
this situation, in addition to having the option to do so. It was concluded that some
High Court decisions that adopted a different stance were to be regarded as having
been made wrongly.

22
Sathappa Chettiar v. Ramanathan Chettiar, 1958 SCR 1024.
23
Meenakshisundaram Chettiar v. Venkattachalam Chettiar, AIR 1979 SC 989.
24
Kanai Lal Sur v. Paramnidhi Sadhukhan, 1958 SCR 360.

8
Ascertaining the process of valuation of suits through relevant judicial
pronouncements

In Nemi Chand v. Edward Mills Co. Ltd.25, the Court determined that while
section 12 of the Court-Fees Act declares a decision final, it does not grant such
decisions total immunity from scrutiny by a higher court. Rather, it means that the
parties cannot challenge the decision by filing an appeal. Stated differently, section
12, which specifies that the decision shall be final between the parties, does
nothing more than put the Court's decision on the matter of Court-fee non-appeal
on par with other interlocutory non-appeal orders under the Code.

In the event that a decision made under section 12 is made by assuming


jurisdiction that the Court does not have or by failing to follow the formalities
required to make such a decision, the High Court may, in the exercise of its
revisional powers, modify the order. In a similar vein, if a party believes that a
decision made under section 12 is manifestly incorrect, he or she may challenge
the interlocutory order even on the Court-fee issue raised in the suit or appeal. This
is because the party may choose to appeal from the order rejecting the plaint or
from the decree dismissing the suit, but not from the decision on the matter of
Court-fee. When used in the narrow meaning that statutes frequently do, the word
finality simply means that there is no appeal from an order of this type in and of
itself.”

In Gopalakrishna Pillai v. Meenakshi Ayal26, the Supreme Court's primary


concern was whether or not the High Court's award of future mesne profit was
legal. In this case, the court established that it has the authority to award future
mesne profit even though the plaint's prayer only addresses past mesne profit and
the court expenses are only paid in relation to past mesne profit. Additionally, it
was established that, with respect to past mesne profits, the plaintiff had an

25
Nemi Chand v. Edward Mills Co. Ltd., 1953 SCR 197: AIR 1953 SC 281.
26
Gopalakrishna Pillai v. Meenakshi Ayal, 1966 Supp SCR 128.

9
established cause of action on the day the suit was instituted. The plaintiff must
then plead, seek a decree for the claim after appraising it roughly, and pay the court
fee in accordance with that claim. Regarding future mesne profit, the plaintiff has
no cause of action on the date the suit is instituted. As a result, he cannot value or
allege this cause of action, and he cannot pay court costs associated with it at that
time. However, the Court had the discretionary authority to issue a decree ordering
an investigation into potential future profits, and even if this relief was not
requested directly, the Court may nonetheless give it.

In Shamsher Singh v. Rajinder Prashad27, the Court-Fees Act, 1870, section 7(iv)
(c), which calculates the Court-fee in a claim for a declaratory decree and
consequential relief, is being interpreted. The Court established that although the
amount of court fees that must be paid on a plaint would undoubtedly be
determined based on the claims and the prayer included in the plaint, the court will
not be concerned at that point with whether the plaintiff's suit must fail for failing
to request consequential relief. When addressing the Court-fee issue, the Court
ought to consider the claims made in the plaint in order to determine the nature of
the requested substantive relief. The court will not be prevented from considering
the content of the relief requested by mere cleverness in the plaint's writing.

So, in reality, the plaintiffs were requesting either the setting aside of the decree or
the consequential relief of an injunction prohibiting the decree-holder from
carrying out the decree against the mortgaged property as he was entitled to do,
when they filed a lawsuit seeking a declaration that the decree obtained by the
appellant against their father was not binding on them. Even while the relief
mentioned in the prayer clause is written in a declaratory manner, this does not
always mean that the lawsuit is only seeking a declaration. The lawsuit would be
covered by article 17 if the relief so revealed is a declaration that is pure and
simple and does not involve any additional relief (iii).”

27
Shamsher Singh v. Rajinder Prashad, (1973) 2 SCC 524.

10
The case of Gopal Chandra Jena v. Laxmi Narayan Bijo Maura Alava 28, upholds
the legal precedent established in the previously mentioned cases with regard to
claims covered by section 7(iv)(c). Specifically, in a suit covered by section 7(v)
(c), the plaintiff is entitled to specify the value of the relief. This clause differs
from section 7(v), which deals with cases involving the possession of properties,
homes, and gardens when the subject matter dictates the valuation. The
aforementioned part also includes guidelines for determining the subject matter's
value in various situations. Given that the legislature has distinguished between
suits falling under sections 7(iv) and 7(v), this indicates that the plaintiffs'
valuation under section 7(iv)(c) is not to be based on the subject-matter valuation,
and it is not permissible to raise the objection that the suit must fail if the plaintiff
fails to value the relief based on the land's market value.

In State of Punjab v. Dev Brat Sharma & Ors.,29 the court determined that if the
matter is a money suit for damages and compensation, then ad valorem court costs
would be due based on the amount sought under Section 7(i) of the Court costs
Act, 1870. It further concluded that the plaintiff is only permitted to state in the
plaint the sum at which relief is valued in cases pertaining to those mentioned in
clause (iv) of Section 7.

Conclusion
The Code of Civil Procedure, 1908 states that valuing a case is an important phase
in the legal process that has wide-ranging implications. It determines court costs,
guarantees that cases are filed in the appropriate courts, stops forum shopping, and
affects the admissibility of claims. Accurate evaluation is necessary to protect the
integrity and efficacy of the legal system as well as the principles of justice and
fairness. For plaintiffs seeking justice in the civil court system as well as for
attorneys, figuring out the suit value is essential. The suit's value is a crucial
component in the development of civil litigation.

28
Gopal Chandra Jena v. Laxmi Narayan Bijo Maura Alava, AIR 1990 Ori 98.
29
State of Punjab v. Dev Brat Sharma & Ors, 1966 Supp SCR 128.

11
Its broad impact reverberates across the legal system, including determinations
regarding jurisdiction, court expenses, and the potency of claims. The Code of
Civil Procedure, 1908, addresses these aspects in great detail and lays the
groundwork for an impartial and just legal system. The nuances of suit value are
important for litigants, legal experts, and the court system to comprehend.
Following the guidelines in these articles, the legal community upholds the
integrity of justice while encouraging the prompt and effective resolution of civil
disputes. By analysing the aforementioned provisions and case laws, one can
discern and ascertain the process of valuation of suits.

Bibliography

 Chiapello, Eve. “Financialisation of Valuation.” Human Studies 38, no. 1


(2015): 13–35.
 Das, J.K. “RETHINKING THEORETICAL FOUNDATIONS OF THE
CODE OF CIVIL PROCEDURE: PROSPECT AND RETROSPECT.”
Journal of the Indian Law Institute 53, no. 1 (2011): 1–31.
 “The Code of Civil Procedure in India.” Journal of the Society of
Comparative Legislation 8, no. 2 (1907): 235–38.
 Gajaseni, “The civil procedure code”, Sutra Paisal Law Media, 2002,
pg.235.
 Ghosh, Priyabrata. “CIVIL JUSTICE SYSTEM: ITS DELAYS AND
SOLUTIONS.” Journal of the Indian Law Institute 41, no. 2 (1999): 264–
71.
 State of Punjab v. Dev Brat Sharma & Ors, 1966 Supp SCR 128.
 Shamsher Singh v. Rajinder Prashad, (1973) 2 SCC 524.
 Gopal Chandra Jena v. Laxmi Narayan Bijo Maura Alava, AIR 1990 Ori
98.
 Nemi Chand v. Edward Mills Co. Ltd., 1953 SCR 197: AIR 1953 SC 281.
 Gopalakrishna Pillai v. Meenakshi Ayal, 1966 Supp SCR 128.

12
 Sathappa Chettiar v. Ramanathan Chettiar, 1958 SCR 1024.
 Meenakshisundaram Chettiar v. Venkattachalam Chettiar, AIR 1979 SC
989.
 Kanai Lal Sur v. Paramnidhi Sadhukhan, 1958 SCR 360.
 Balireddi v. Khatipulal Sab, AIR 1935 Mad 863.
 P.K. Vasudeva Rao v. Hari Menon, AIR 1982 Ker 35.
 Venkata Narasimha Raju v. Chandrayya, AIR 1927 Mad 825.
 Padma Sundara Rao (Dead) v. State of Tamil Nadu, (2002) 3 SCC 533.
 R. Rangiah v. Thimma Setty, (1963) 1 Mys LJ 67.
 Chief Inspector of Stamps v. Indu Prabha Vachaspati, (1998) 9 SCC 157.
 Allam Venkateswara Reddy v. Golla Venkatanarayana, AIR 1975 AP 122.
 Smt. Narbada v. Smt. Aashi, AIR 1987 Raj 162.
 Gurudevdatta VKSSS Maryadit v. State of Maharashtra, (2001) 4 SCC 534.
 Osborough, Nial. “Court Fees.” Irish Jurist (1966-) 9, no. 2 (1974): 318–
19.
 MAXEINER, JAMES R. “Cost and Fee Allocation in Civil Procedure.”
The American Journal of Comparative Law 58 (2010): 195–221.
 Tupper, Lewis. “The Indian Code of Civil Procedure.” Journal of the
Society of Comparative Legislation 9, no. 1 (1908): 69–78.
 Dodson, Scott. “COMPARATIVE CONVERGENCES IN PLEADING
STANDARDS.” University of Pennsylvania Law Review 158, no. 2 (2010):
441–72.
 Chiapello, Eve. “Financialisation of Valuation.” Human Studies 38, no. 1
(2015): 13–35.
 “The Code of Civil Procedure in India.” Journal of the Society of
Comparative Legislation 8, no. 2 (1907): 235–38.
 Gajaseni, “The civil procedure code”, Sutra Paisal Law Media, 2002,
pg.235.
 Ghosh, Priyabrata. “CIVIL JUSTICE SYSTEM: ITS DELAYS AND
SOLUTIONS.” Journal of the Indian Law Institute 41, no. 2 (1999): 264–
71.

13

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