Date and Time: Tuesday, 19 March 2024 1:56:00AM IST

Job Number: 219767537

Document (1)

1. CHAPTER 6 KARTA
Client/Matter: -None-

| About LexisNexis | Privacy Policy | Terms & Conditions | Copyright © 2024 LexisNexis
 CHAPTER 6 KARTA
Kusum & Poonam Pradhan Saxena - Family Law
Poonam Pradhan Saxena

Kusum & Poonam Pradhan Saxena - Family Law > Kusum & Poonam Pradhan Saxena - Family
Law > VOLUME II

CHAPTER 6 KARTA

INTRODUCTION
Joint family is a unique institution under Hindu Law. It is an institution whose members own property in its name,
which has several persons as its members, having distinct rights over the property, and rights and obligations
towards each other. As a unit, it deals with outsiders and even statutory authorities, and therefore, it becomes
imperative that as a unit, it must be headed by a person from within the family who is not only capable of
representing it in law and virtually all matters, but is also competent to bind all family members with his bona fide
actions or decisions taken with respect to the family, and its property. He should also be a person who can
generally be trusted to act in the best interests of the family.

Ancient family units were headed by the seniormost male member in the family, the ‘Patriarch,’ who had more or
less an absolute control over the property and even over the lives of the family members. He was the unquestioned
ruler of the family, he represented the family in all matters and his decisions were final as he was obeyed by all
members. The conferment of near absolute control went hand in hand with the promotion of family welfare as his
implied responsibility. Presently, the basic framework has remained the same, but the powers of the head of the
family have been considerably diluted. Absolute powers have been replaced by superior powers co-existing with
superior responsibilities. The term ‘Patriarch’ has been replaced with ‘Karta’,1 also described as ‘Manager’ (an inapt
translation into English language) of the Hindu joint family.

WHO CAN BE A ‘KARTA’

The father and in his absence, the seniormost male member is presumed to be the Karta of a Hindu joint family.2
The presumption is very strong as this position is regulated by seniority3 and does not depend upon merely the
consent of the other family members. A temporary absence of the father is not sufficient for the son to become a
Karta, if there is nothing to show that the father is in a remote country or his whereabouts are not known or his
return within a reasonable time is out of question.4 Therefore, so long as the Karta is alive no one else on his own
can be a Karta, and if the Karta so desires, he continues to occupy the representative capacity even though he may
be inadept to look after the family affairs by reasons of age or health. If he does not want to continue as the Karta,
he can expressly relinquish this position and with the concurrence of the family members, another coparcener, not
necessarily the next in seniority, may be appointed as the Karta.5 But, for this, the agreement of all the members is
necessary6 and in the case of a conflict, the seniormost will be presumed to be and would continue as the Karta.
The mere fact that a younger brother joins the elder brother in some transactions of the family, would not adversely
affect the position of the elder brother as the Karta.7 Even a minor can act as the Karta and represent the family
through the guardian.8

Two persons may look after the management of the property,9 but the joint family can be represented only by one
Karta.10 Therefore, there is no scope for two ‘Kartas’ or two representatives. There can be one and only one Karta.
On the death of the Karta, the next male in seniority will become the Karta and if there are some legal proceedings
pending in the court involving the joint family, his name will be substituted as the representative of the family, in
place of the deceased Karta.11
 Page 2 of 7
CHAPTER 6 KARTA

JUNIOR MEMBER OF COPARCENARY AS KARTA

It is a settled principle of Hindu law that the position of Karta in the joint family goes to a person by birth and is
regulated by seniority and the Karta/manager occupies a position superior to that of the other members. A junior
member cannot therefore deal with the joint family property as a manager so long as the Karta is available except
where the Karta relinquishes his right expressly or by necessary implication or in his absence in exceptional and
extraordinary circumstances such as distress or calamity affecting the whole family and for supporting the family or
where his whereabouts were not known or he was away in a remote place due to compelling circumstances and his
return within a reasonable time period was unlikely or not anticipated12.

In Nopany Investments (Pvt) Ltd. v. Santokh Singh 13, the Karta of a Hindu joint family was staying in the United
Kingdom and was not in a position to handle the joint family affairs in India. He executed a power of attorney in
favour of his younger brother and the whole family accepted the latter’s management of the joint family affairs
without any protest. This younger brother filed a suit for eviction against the tenant, and the tenant raised a
preliminary objection that as he is not the Karta, the suit for eviction filed by him does not hold good in law. The
Court dismissed the contention of the tenant and observed that it was not open for the tenant to raise such a kind of
objection with respect to the maintainability of the suit at the instance of the younger brother as the records clearly
showed that all along it was the younger brother of the Karta who was realizing the rent from the tenant and the
tenant is now stopped from raising any such question, and the suit was maintainable at the instance of the younger
brother claiming himself to be the Karta of the joint family despite the fact that he was not the senior most male
member of the Hindu Joint family. The court held that where the Karta of the joint family is away in a foreign land for
a long time and his return within a short time period is unlikely and due to his absence he cannot look after the
affairs of the Hindu joint family, a younger member of the coparcenary with the consent of all the members of the
family can act as the Karta of the family. He is also empowered to enter into transactions on behalf of the joint
family, such as execution of a lease or filing a suit for eviction of the tenant inducted into the joint family premises.
The court here clarified that though the settled principle of classical Hindu law remains that Karta would be the
senior most male member of the family in the following circumstances a younger brother of the joint Hindu Family
can deal with the family property as Karta:

(i) if the senior member or the Karta is not available

(ii) where the Karta relinquishes his right expressly or by necessary implication;
(iii) in the absence of the manager in exceptional and extraordinary circumstances such as distress or calamity
affecting the whole family and for supporting the family ;
(iv) in absence of the father;
(v) father’s whereabouts are not known
(vi) who was away in a remote place due to compelling circumstances and his return within a reasonable time
was unlikely or not anticipated.

Females as Karta

The position of the Karta is regulated by birth and is guided by seniority. For being a Karta and to be entitled to
manage the family affairs, including the property, it is essential that the Karta is capable of acquiring an interest in
the family property. The Karta, therefore, must have not merely an interest of residence and maintenance, but of
ownership in this property. A daughter is born in the family, but ceases to be a member of the family on her
marriage. In contrast, other female members become members of the joint family on their marriage to lineal male
descendants, but are not born in this family. Therefore, a position that is regulated by birth cannot be conferred on
these females. Secondly, to be a Karta, it is essential that not only should he be a male, but he should also be a
coparcener, as a non-coparcener male cannot become a Karta.14

Since a female is not a coparcener,15 she cannot be a Karta,16 nor is she empowered to represent the family
generally.17 However, Nagpur High Court has held18 that under certain special situations, even a female can act as
a Karta and her decision would be binding on the family members. This decision does not appear to be correct, as
she is neither a coparcener, nor is she entitled to a share in the coparcenary property. On behalf of a minor
coparcener, she can act as a guardian, but that would not make her the Karta. A mother, therefore, cannot be a
Karta.19 A wife cannot act as the Karta in absence of her husband,20nor can she act as the Karta in a joint family
 Page 3 of 7
CHAPTER 6 KARTA

comprising her husband and her son.21 Similarly, a Hindu widow cannot be a Karta, even if rights are conferred on
her, in the deceased husband’s coparcenary property.22

POSITION POST 1985

Beginning with 1985, till 1994, the States of Andhra Pradesh (1985), Tamil Nadu (1989), Maharashtra and
Karnataka (1994) introduced the possibility of unmarried daughters being coparceners in the same manner as a
son. Since now, in these states, upon marriage, a daughter continues to be a coparcener, she fulfils the
requirements for becoming a Karta. Born in the family, she acquires an interest in the coparcenary property and
therefore, she can be a Karta, if she is the seniormost member in the family and she will be entitled to represent the
family in all legal proceedings.23

POSITION POST 2005

Presently, a daughter is a coparcener in the same manner as a son. Since she is a coparcener, she is also entitled
to be a Karta and represent the family in all matters.

POSITION OF KARTA
The position of a Karta is sui generis. It comes to him by being born in the family and is regulated by seniority. It is
terminable by resignation and relinquishment but is not indefeasible. It is a unique position and the relation between
him and the other family members is difficult to explain, as it has no parallel in any other kind of relationship. He is
the custodian of the family interest and his actions are backed by a presumption of the promotion of general family
affairs. He is the head of the family, but the relationship is not that of principal and agent24 under the Contract Act,25
nor even of partners. It is at best, comparable to that of a trustee,26 as he stands in a fiduciary relationship with the
other members of the family, but unlike a trustee, he is not accountable to the family generally, and even where he
mis-manages or incurs a loss while managing the family affairs, unless he is charged with fraud or misappropriation
of the joint family property his actions and decisions are binding on all the members of the family, including those
who may not like his decisions. The Karta cannot be held liable for negligence27 and where he acts honestly and
with bonafide intentions, in the best interests of the family, his discretion cannot be closely scrutinised,28 but where
he misappropriates the joint family funds or uses them for purposes other than for family benefits, he is accountable
and will be called upon to refund the amount to the joint family corpus.29

RESPONSIBILITIES OF KARTA
The superior position of a Karta is saddled with superior responsibilities. He has the primary responsibility of
providing food, shelter, clothing, or in other words, a residence and maintenance to all the family members. This
also includes a responsibility to provide for marriage expenses of unmarried children, more specifically the
daughters, and for funeral expenses of the departed members. As he represents the family, he has to defend the
family in all litigations that may be filed against the family, by a member of the family or outsiders. As he manages
the property, he has the responsibility to pay all the statutory or other dues, such as taxes, debts etc, due to the
family or to the family property.30

REMUNERATION FOR SERVICES

The position of a Karta is purely honorary and he is not entitled to draw or receive any salary for the services
rendered, unless there is an agreement to this effect. In the absence of such an agreement, money received by him
while managing the family affairs, would belong to the family and not to him alone. This also distinguishes his
position as the Karta from that of a manager of any concern, holding property in common, where the manager’s
work would undoubtedly fetch him a salary or a share in the profits. A Karta’s labour is perceived with sanctity. As
the head of the family, he is expected to selflessly and without expecting a monetary return, discharge his duties for
 Page 4 of 7
CHAPTER 6 KARTA

the welfare of the family. It is comparable to the labour involved and efforts taken by parents to raise their children
and cannot be measured with a price tag. However, in cases where the Karta uses his time and labour in looking
after the family affairs or conducting the family business, where he could have spent the same time in a full fledged
avocation, there is no reason why he should not get a monetary return for it. Therefore, if in pursuance to an
agreement, he agrees to receive a salary, the agreement would be valid and the family can show it as an
expenditure in the income tax returns. No third party, including the income tax officer, can challenge the validity of
such an agreement. The Supreme Court, in Jugal Kishore’s case,31 while adjudicating on the dispute as to whether
a Karta can be granted a remuneration for managing the family business, observed:

The general view expressed by commentators on Hindu law, as well as in decided cases, is that the Karta of a family can
be paid remuneration for carrying on the family business, provided it is under some agreement. There seems to be no
reason why, if all the persons competent in a Hindu undivided family, to enter into an agreement on its behalf, consider it
appropriate that the Karta should be paid remuneration and enter into an agreement to pay remuneration to him, that
remuneration should not be held as an expenditure deductible under the Income Tax Act.

The court seems to have distinguished between the right of the Karta to manage the family affairs and conducting
the family business. It held that the Karta has a right to manage the family affairs but he is under no obligation or
duty to carry a particular business of the family, and where a junior member of the family conducts the business of
the family and is granted a salary for doing so, there is no reason why the Karta cannot be granted the same.
Treating it as essentially, a matter between the family members, it held that it would be treated as an expenditure of
the family. In Ashok Kumar v. Commissioner of Income Tax, Amritsar, 32 a Hindu joint family consisted of the father,
his wife and two minor children. The father was looking after the family business. He, as the Karta of the family, and
his wife entered into an agreement, pursuant to which he was empowered to draw a salary of Rs. 500 per month,
as remuneration for the services rendered by him in conducting the business. This salary paid to him, was shown
as an expense of the family in the income tax returns that he filed as the Karta. The income tax officer, however,
disagreed with him and argued that such an agreement was invalid, as a Karta is not entitled to draw any salary for
the work that he is under a duty to perform, and that therefore, it is not an expense that will be deducted from the
income of the family. The Jammu and Kashmir High court, following the Apex Court’s judgment, held that the Karta
is empowered to draw a salary pursuant to an agreement and no third party is empowered to challenge the validity
of such an agreement, as it is a matter essentially between the family members.

POWERS OF THE KARTA

Power to Manage Family Affairs

The Karta is the head of the family and has the power to manage the family affairs and the family property. It is said
that though his powers of alienation are limited, his powers of management are absolute.33 He has the power to
take possession of the total property and receive the joint family income from whichever source it may come. No
individual coparcener can either retain the exclusive possession of a specific joint family property or joint family
income, without his permission. If a coparcener insists on possessing a specific portion of the property without the
consent of the Karta, the Karta can evict him from that portion.34 If a coparcener’s presence in the family home
proves to be a nuisance due to his disorderly behaviour or bad habits, the Karta has the power to throw him out of
the house. The coparcener cannot challenge his decision and the only remedy available with him is to ask for
partition, specify the share and go out of the family.

The Karta, therefore, has a right to decide or allot specific portions of the house for family member’s residence,
which the latter have to obey. While taking decisions with respect to family members, the Karta need not be
equitable or even impartial. He can bestow excessive favoritism on one child in comparison to another, he can give
a specific reasonable sum of money to one son for his maintenance, while on others, he can spend lavishly. It is he
who has to decide, how much is to be spent on each person’s education and no one can legally interfere with his
decision. He may or may not pay a fixed amount of maintenance to any member, and even if he enters into any
kind of agreement to this effect, he is free to repudiate it at his pleasure, only to enter into any other kind of
arrangement, or no agreement at all. If there is an emergency that requires an application of money, issues like
from where the money is to be raised, whether it is to be raised at all or not and what action is to be taken, would be
for the Karta to decide, as that is an inherent part of management. No member of the family, and for that matter, not
even the court, can force the Karta to take a particular decision, as that would mean an interference in his inherent
powers of management.
Right of Representation
 Page 5 of 7
CHAPTER 6 KARTA

The Karta has a right to represent the family in all legal, social, religious and revenue matters, including litigations,35
with respect to matters connected with immovable properties or otherwise. A suit will be filed in a court by the family
in his name and likewise, a suit filed against the family will be defended by him. The joint family, therefore, acts
through the Karta, as it has no corporate existence, and a decree passed against the Karta binds all the members,
including minors,36 irrespective of the fact that they were not direct parties to the suit. It is presumed that the Karta
represents the family in all legal proceedings and there may not be a specific mention of him being in the
representative capacity,37 unless it can be shown that he himself is claiming an interest that adversely affects the
interests of the family.38 The Karta is expected to pursue the litigation with utmost sincerity, but if he does not do so
and because of this, the family loses a case or a decree is passed against the family, such decree cannot be set
aside on the ground that, had the Karta been more vigilant, the family might have won the case.39 Similarly, where
the father represents the minors in a suit, the contention that his actions are not in the interests of the minors, will
not alter the binding nature of the judgment.40
Power to receive and spend the Family Income

As aforesaid, the right to receive the joint family income is one of the inherent powers of the Karta, in the exercise of
the management of joint family affairs. The income, from whichever source, will be received by him. The decision of
how to spend this joint family income and on whom to spend it, is with the Karta. He is not under any obligation to
economise or save, as in the case of an agent or a trustee.41

The Karta can spend the income for the maintenance of family members and for one of the permitted purposes,42
i.e., legal necessity, benefit of estate and for performance of religious and indispensable duties. He can spend the
money for providing for the residence of the family members, including for the maintenance of a destitute
daughter.43
Powers of Alienation

The Karta’s power of alienating the joint family property are limited or qualified, and can be exercised with the
consent of all the coparceners. Where the coparcener does not give consent or is incapable of giving consent,
being a minor, the Karta can alienate the property only for legal necessity or for performance of religious or
charitable purposes or where the transaction would amount to benefit of estate. In such cases, the alienation would
bind all the members of the family, including minors.44 In the case of an unauthorised alienation, the coparceners
have a right to challenge it and get a decree setting it aside.
Liability to Account

The Karta is not bound to keep accounts of how he has spent the family funds, as he is presumed to act in the best
interests of the family, but where a coparcener demands partition, he can require the Karta to give him accounts.45
The Karta has to give him accounts for the money he had actually received and not what he could have received if
he had managed the property in a better manner.46 Further, he can only be asked to render the accounts as they
existed on the date of the demand47 and he cannot be forced to render past accounts,48 unless there are charges of
fraud, misappropriation or conversion of joint family property into his personal acquisitions,49 or the nature of
business is such that necessitates proper accounting at all times. In such cases, the Karta has to give accounts to a
member demanding it,50 at the time of partition. The coparcener can also refute the stand of the Karta where the
accounts are not acceptable to him, on the ground that either the Karta has not spent the money that he claims to
have spent,51 or the Karta has not been honest in showing the properties available for partition and has not included
all the joint family properties.

In Bengal, however, for families governed by Mitakshara or Dayabhaga law, a coparcener has a right to require the
Karta to give him accounts of the dealings with respect to the joint family property, including that of the income and
profits thereof and upon a refusal by the Karta to do the same, a coparcener can take the help of the court by filing
a suit for the rendition of accounts.52
Power to Acknowledge and Contract Debts

The Karta has the authority to acknowledge debts due to the family and to pay interest on it,53 though he cannot,
however, revive a time barred debt.54 The debt might have been contracted by all members of the family or by the
Karta alone, acting on behalf of the family. The Karta also has the power to contract debt for using the loan in family
business or for any other lawful purpose and such a debt binds the share of all the coparceners. A coparcener,
even after seeking partition, cannot escape the liability of the debt contracted by the Karta, from his share of the
property. Where a loan is raised by the Karta by executing a promissory note in his name, but for a lawful purpose,
such a note binds the other coparceners, but only to the extent of their shares,55 unless it can be shown that they
were parties to this contract.56
 Page 6 of 7
CHAPTER 6 KARTA

Power to settle Family Disputes

In case of a dispute between the members of the family or between family members and outsiders, the Karta can
refer the dispute for arbitration.57 He can also enter into a compromise on behalf of the family, but not where such a
compromise is for his personal advantage.58 Where such reference to arbitration or compromise is for the benefit of
the family,59 all family members including minors, are bound by it.60

1. See Suraj Bunsi Koer v. Sheo Persad, (1880) ILR 5 Cal 148.
2. A. Kunjipokkarukutty v. A Ravunni, AIR 1973 Ker 192 ; Varoda Bhaktavatsaludu v. Venkata Narasimha Rao, 1940 Mad
530 .
3. Lalbarani v. Bhutnath, AIR 1974 Cal 109 [LNIND 1973 CAL 165]; Himchandra v. Matilal, (1933) ILR 60 Cal 1253;
Jasoda Sundari v. Lal Mohan Basu, AIR 1926 Cal 361 .
4. Siddappa v. Linappa, 42 Mys HCR 669.
5. Nemi Chand v. Hira Chand, (2000)1 HLR 250 (Raj).
6. Mudit v. Ranglal, (1902) ILR 29 Cal 797; Narendra Kumar v. Commissioner of Income Tax, AIR 1976 SC 1953 [LNIND
1976 SC 247].
7. Ghasi Ram v. Hiralal, AIR 1954 MP 67 .
8. Sarda Prasad v. Umeshwar Prasad, (1963) ILR Pat 274; Budhi Jena v. Dhobai Naik, AIR 1958 Ori 7 .
9. Union of India v. Shree Ram, AIR 1965 SC 1531 [LNIND 1965 SC 18].
10. Damodar Misra v. Sanamali Misra, AIR 1967 Ori 61 .
11. Chandradip v. Jagannath, AIR 1978 Cal 157 [LNIND 1976 CAL 178].
12. Tribhovan Das Haribhai Tamboli v. Gujarat Revenue Tribunal, (1991) 3 SCC 442 [LNIND 1991 SC 282] : (1991) SCW
1467.
13. AIR 2008 SC 673 [LNIND 2007 SC 1445].
14. For the position post 2005 see the discussion infra.
15. Commissioner of Income Tax v. Govindram Sugar Mills, AIR 1966 SC 24 [LNIND 1965 SC 572];Manglal v. Jayabai,
AIR 1994 Kant 276 [LNIND 1994 KANT 84]; Kanji v. Parmanand, AIR 1992 MP 208 [LNIND 1991 MP 172].
16. Sahdeo Singh v. Ramchabila Singh, AIR 1978 Pat 258 .
17. Ram Avadh v. Kedar Nath, AIR 1976 All 283 .
18. (1947) ILR Nag 299; Commissioner of Income Tax v. Lakshmi Narang, (1948) ILR Nag 775.
19. Magunti v. Lingaraj, AIR 1956 Ori 1 .
20. Sheogulam v. Kisun Choudhuri, AIR 1961 AP 212 .
21. Krishnayya v. Balavankata Subbayya, (1968) 1 Andh LT 197.
22. Radha Ammal v. Commissioner of Income Tax, (1951) ILR Mad 56.
23. See Chapter IV, supra.
24. Kandasami Asari v. Somaskanda, (1912) ILR 35 Mad 177 .
25. Muhammad v. Radha Ram, (1900) ILR 22 All 307; Sirkant Lal v. Sidheshwari Prasad, AIR 1937 Pat 455 .
26. Perrazu v. Subbarayadu, AIR 1922 PC 71 .
27. Raya v. Gopal, 11 IC 666.
28. Vaikuntam v. Avudiappa, 1937 Mad 127 .
29. Abhay Chandra v. Pyari Mohan, 5 Beng LR 347.
30. Lalitha Kumari v. Rajah of Vizianagram, 1954 Mad 19 .
31. Jugal Kishore Baldeo Sahai v. Commissioner of Income Tax, (1967) 63 ITR 238, 242; see also Jitmal Bhuramal v.
Commissioner of Income Tax, (1962) 44 ITR 887.
32. Ashok Kumar v. Commissioner of Income Tax, Amritsar, IT Reference 17/ 1982, decided on 19 July, 2000 (J&K).
 Page 7 of 7
CHAPTER 6 KARTA

33. Bhaskaran v. Bhaskaran, (1908) ILR 31 Mad 318 .

34. Baldeo Das v. Shamlal, (1876) ILR 1 All 77.
35. Singriah v. Ramanuja, AIR 1959 Mys 239 (DB).
36. Rajayya v. Singa Reddy, AIR 1956 Hyd 200 .
37. Narain Sarup v. Daya Shanker, (1938) ILR All 455; Devi Das v. Shailappa, AIR 1961 SC 1277 [LNIND 1961 SC 408];
Govindarajulu v. Sivaramakrishnan, 1953 Mad 822 .
38. Papamma v. Narayana, 1948 Mad 54 .
39. Krishnamurthi v. Chidambaram, (1946) ILR Mad 670.
40. Gurbasappa v. Vankat, AIR 1956 Hyd 146 (DB).
41. Bhowani v. Jagannath, (1909) 13 CWN 309.
42. See Chapter 8, ‘Alienation of Joint Family Property’, infra.
43. Ramayya v. Kolanda Goundan, (1940) ILR Mad 322.
44. VVV Ramaraju v. Korada Malleswara Rao, (1999) 2 HLR 257 (AP).
45. Girijanandini Devi v. Brijendra Narain, AIR 1967 SC 1124 [LNIND 1966 SC 149].
46. Official Assignee v. Rajabadar, (1924) 40 Mad LJ 145; Kanahayalal v. Jumma Devi, AIR 1973 Del 160 ; Vishwa v.
Prem Nath, AIR 1975 J&K 92 .
47. Gopal v. Trimbak, AIR 1953 Nag 195 ; Ramanathan v. Narayanan, 1955 Mad 629 ; Ramnath v. Goturam, AIR 1920
Bom 236 .
48. Bappu Ayyar v. Renganayaki, 1955 Mad 394 ; Sukhdeo v. Basudev, AIR 1935 All 594 .
49. Suryanarayana v. Sugamanathi, AIR 1961 AP 393 [LNIND 1960 AP 233]; Seethamma v. Veerannachetty, 1950 Mad
785 .
50. Girijanandini Devi v. Brijendra Narain, AIR 1967 SC 1124 [LNIND 1966 SC 149].
51. Manaharanlal v. Jagiwanlal, AIR 1952 Nag 73 ; Tammireddi v. Gangireddi, 1922 Mad 236 .
52. Benoy Krishna Ghosh v. Amrendra Krishna Ghosh Choudhri, AIR 1940 Cal 51 ; Abhaychandra v. Pyari Mohan, (1870)
5 Beng LR 347.
53. Ananda Charan v. Jhatee Charan, AIR 1935 Cal 648 ; Nagarmal v. Bajranglal, (1950) 77 IA 22; Ram Autar v. Beni
Singh, AIR 1922 Oudh 135 .
54. Nallamilli Veerayamma v. Karri Ammireddi, (1949) 1 Mad LJ 189.
55. Krishnanand v. Raja Ram Singh, AIR 1922 All 116 .
56. Sirikant Lal v. Sidheshwari Prasad, AIR 1937 Pat 455 .
57. Jagananath v. Mannu Lal, (1894) ILR 16 All 231.
58. Bhola Prasad v. Ramkumar, (1932) ILR 11 Pat 399; Mahabir Prasad v. Ram Tahal, (1937) ILR 16 Pat 724.
59. Lakhmichand v. Kolloolal, (1956) ILR Nag 783; Ramji Ram v. Salig Ram, (1911) 14 CLJ 188.
60. Nawal Kishore v. Sardar Singh, AIR 1935 Lah 667 ; Datta Mal v. Amar Nath, AIR 1938 All 414 .

End of Document