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FINAL-TERM ASSIGNMENT (ADR)

COURSE: L.L.M
SUBJET: ALTERNATE DISPUTE RESOLUTION
SUBMITTED TO: SIR MUHAMMAD YAQOOB.
SUBMITTED BY: ATIQ AHMAD
SEMESTER: 4TH (SPRING, 2021)
SESSION: FALL (2019)
ROLL NO: A.LLM010151269
MOBILE: 0343-9459771

POST GRADUATE INSTITUTE OF LAW

UNIVERSITY OF LAHORE
Date: 10/July/2021
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Assignment Question:
“Ultimate success in the dispute resolution field will require a broad
effort to expand our presently limited understanding. Progress will
require continued experimentation and research, as well as attempts
to conceptualize the field. Enhanced public education about the
benefits to be derived from alternative modes of dispute settlement
will be necessary. Above all, the ADR movement will require the
broadened involvement and support not only of the legal and legal
education establishments, but also on the political and social orders
and the public at large. The potential benefits are simply too great to
leave these challenges unmet.”
Discuss with reference to promotion of ADR mechanism in Pakistan
legal system.
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1. Introduction

“Discourage litigation; persuade your neighbors to compromise

whenever you can. Point out to them how the nominal winner is
often a real loser – in fees, expenses, and waste of time. As a
peacemaker, the lawyer has a superior opportunity of being a
good man. There will still be business enough.”

Abraham Lincoln.

Alternate Dispute Resolution (ADR) first started as a quest to find solutions

to the perplexing problem of the ever increasing burden on the courts. It was an
attempt made by the legislators and judiciary alike to achieve the “Constitutional
goal” of achieving Complete Justice. ADR by means of Arbitration, Conciliation,
Negotiation, Mediation, is introduced in Pakistan following USA and many other
countries where ADR is very successful mechanism to solve the disputes outside the
courts. But Pakistan is still lacking behind in developing the ADR mechanism due to
several reasons.

Despite many advantages of using Alternative dispute resolution mechanisms,

our society has been reluctant to give it its due recognition. The predominant reason
being that a litigation ridden society is generally unable to explore consensual
dialogue or arrive at an amicable solution. The ADR practitioner therefore acts like a
healer of conflicts rather than a combatant. It is similar to the Panchayat system we
have in our villages. The resolution of disputes is so effective and widely accepted
that Courts (In sitanna v. Viranna; AIR 1934 SC 105, the Privy Council affirmed
the decision of the Panchayat and Sir John Wallis observed that the reference to a
village panchayat is the time-honoured method of deciding disputes) have more often
recognized them. It avoids protracted litigation and is based on the ground realities
verified in person by the adjudicators and the award is fair and honest settlement of
doubtful claims based on legal and moral grounds.

2. Definition of ADR
Alternative dispute resolution (ADR) (also known as external dispute
resolution in some countries, such as Australia) includes dispute resolution processes
and techniques that act as a means for disagreeing parties to come to an agreement
short of litigation. Despite historic resistance to ADR by many popular parties and
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their advocates, ADR has gained widespread acceptance among both the general
public and the legal profession in recent years. In fact, some courts now require some
parties to resort to ADR of some type, usually mediation, before permitting the
parties’ cases to be tried (indeed the European Mediation Directive (2008) expressly
contemplates so-called “compulsory” mediation; attendance that is, not settlement at
mediation). The rising popularity of ADR can be explained by the increasing
caseload of traditional courts, the perception that ADR imposes fewer costs than
litigation, a preference for confidentiality, and the desire of some parties to have
greater control over the selection of the individual or individuals who will decide
their dispute. Some of the senior judiciary in certain jurisdictions (of which England
and Wales is one) are strongly in favor of the use of mediation to settle disputes.

“Alternative dispute resolution” (ADR) is a term generally used to refer to

informal dispute resolution processes in which the parties meet with a professional
third party who helps them resolve their dispute in a way that is less formal and often
more consensual than is done in the courts. While the most common forms of ADR
are mediation and arbitration, there are many other forms: judicial settlement
conferences, fact-finding, ombudsmen, special masters, etc. Though often voluntary,
ADR is sometimes mandated by the courts, which require that disputants try
mediation before they take their case to court.

3. History of ADR

Although mediation goes back hundreds of years, alternative dispute

resolution has grown rapidly in the United States since the political and civil
conflicts of the 1960. The introduction of new laws protecting individual rights, as
well as less tolerance for discrimination and injustice, led more people to file
lawsuits in order to settle conflicts. For example, the Civil Rights Act of 1964
outlawed discrimination in employment or public accommodations on the basis of
race, sex, or national origin. Laws such as this gave people new grounds for seeking
compensation for ill treatment. At the same time, the women’s movement and the
environmental movements were growing as well, leading to another host of court
cases. The result of all these changes was a significant increase in the number of
lawsuits being filed in U.S. courts. Eventually the system became overloaded with
cases, resulting in long delays and sometimes procedural errors. Processes like
mediation and arbitration soon became popular ways to deal with a variety of
conflicts, because they helped relieve pressure on the overburdened court system.
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Dispute resolution outside of courts is not new; societies world-over have

long used non-judicial, indigenous methods to resolve conflicts. What is new is the
extensive promotion and proliferation of ADR models, wider use of court-connected
ADR, and the increasing use of ADR as a tool to realize goals broader than the
settlement of specific disputes. The ADR movement in the United States was
launched in the 1970, beginning as a social movement to resolve community-wide
civil rights disputes through mediation, and as a legal movement to address increased
delay and expense in litigation arising from an overcrowded court system. Ever
since, the legal ADR movement in the United States has grown rapidly, and has
evolved from experimentation to institutionalization with the support of the
American Bar Association, academics, courts, the U.S. Congress and state
governments.

For example, in response to the 1990 Civil Justice Reform Act requiring all
U.S. federal district courts to develop a plan to reduce cost and delay in civil
litigation, most district courts have authorized or established some form of ADR.
Innovations in ADR models, expansion of government-mandated, court-based ADR
in state and federal systems and increased interest in ADR by disputants has made
the United States the richest source of experience in court connected ADR .

4. Growth of ADR
The growth of ADR, especially mediation, outside the courts, has been
dependent on three concurrent developments:
 Dissatisfaction with the legal process for creating good results,
 Dissatisfaction with cost and delay of court procedures
 Increased legislation on arbitration making arbitration more expensive
and less flexible.
 The dissatisfaction with the procedure itself and the results could to some
degree, be compared to the limited aspects of justice, namely mostly the
distributive, discussed in court,
 And the limited legal remedies.

5. Classification of ADR:

ADR is generally classified into at least four types:

 negotiation,
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 mediation,

 collaborative law

 and arbitration.

 Sometimes a fifth type, conciliation, is included as well, but for present

purposes it can be regarded as a form of mediation.

ADR can be used alongside existing legal systems such as sharia courts
within common law jurisdictions.

6. Advantages and disadvantages

Parties often seek to resolve disputes through arbitration because of a number of
perceived potential advantages over judicial proceedings:

 In contrast to litigation, where one cannot "choose the judge", arbitration

allows the parties to choose their own tribunal.
 Arbitration is often faster than litigation in court.
 Arbitration can be cheaper and more flexible for businesses.
 Arbitral proceedings and an arbitral award are generally non-public, and can
be made confidential.
 In arbitral proceedings the language of arbitration may be chosen, whereas in
judicial proceedings the official language of the country of the competent
court will be automatically applied.
 Arbitration awards are generally easier to enforce in other nations than court
verdicts.
 In most legal systems there are very limited avenues for appeal of an arbitral
award, which is sometimes an advantage because it limits the duration of the
dispute and any associated liability.

Some of the disadvantages include:

 Arbitration may be subject to pressures from powerful law firms representing

the stronger and wealthier party.
 If the arbitration is mandatory and binding, the parties waive their rights to
access the courts and to have a judge or jury decide the case
 There are very limited avenues for appeal, which means that an erroneous
decision cannot be easily overturned
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 Rule of applicable law is not necessarily binding on the arbitrators, although

they cannot disregard the law.
 Peoples` lack of trust of community leadership
 Sometimes faced with biased decisions.
 Fear of losing dignity and prestige
 Persons dealing with ADR lack adequate knowledge and experience and
understanding of ADR.
 Unjustified resemblance with the judicial settlement conferences.

7. A Critical Analysis of the Contemporary Judicial Business of Pakistan

Lack of contemporary legislations for consensual adjudication and

administrative discretions has created such a vacuum in the administration of justice.
It is creating a distress among common men to consult courts as a last resort to their
disputes. The common law system with a winning or losing concept is
counterproductive to pragmatic and sustainable social cohesion, which is an ultimate
objective of the law. Consequently, for a vibrant concept of justice, non-conventional
means for adjudication is a prerequisite of the time in a society like ours, which is
already fragmented and polarized. Thus keeping in mind, the “Permanent Lok
Adalat” experience in neighbouring country India, this study is focusing on an
unconventional adjudication through the experts, in the field of reconciliations,
arbitrations, mediations and negotiations.

Dispensation of justice is a crux of any judicial system. Pakistan’s

overburdened judiciary is facing multidimensional problems which make it
inefficient; it further leads to the incapacity of courts to adjudicate complex issues at
a proper pace of time. Inefficiency of judicial system falls into two categories. First
category deals with unavailability of up to date and sophisticated training and
equipment, revolutionized cyber technology, specifically focused on data based legal
statutes and citations. This category primarily linked with legal and judicial
infrastructure and based on availability of funds as well as transfer of technology
under the wave of globalization. However second category is strategically more
important to study. It deals with implementation and the dispensation of justice,
which is hindered due to complex procedures and alien jurisprudence and
fragmented socio-political indigenous environment. Thus the Court observes,
“Technicalities and legal provisions are meant to advance and not to obstruct
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justice.” Accordingly it is said that the inefficient judicial systems are not compatible
with dynamic, conflicting as well as competing social political and economic needs
of developing countries. Justice Ronald relates it with an absence of Alternative
Dispute Resolution [ADR] or permanent equity courts. He thinks that such kind of
situation promotes rivalry of winning or losing instead of conflict management in
civil society. As a consequence undue burden of litigations leaves behind the menace
of delays and backlogs causing inefficiency of the judicial system. Critics declare it a
time consuming, costly issue as an anti-poor element of courts. Legal experts
recognize such phenomena as, an incapacity of courts to adjudicate, he further and
describes that diminishing capacity of the judiciary has a direct relationship with the
legitimacy of the entire judicial system. Though lawyers and judicial officers are
well versed with procedural technicalities and legal rules, yet the law is a dynamic
field and needs compatible and harmonious changes according to the time and space.
Hence sociological jurisprudence and restorative justice is a mean to deal with the
complex changes of the society where rules are unable to dispense a pragmatic
justice. Prevailing top down authoritarian (Willsonian) model of judicial
dispensation in Pakistan with an agent relative consequentialism is incompatible with
its premise of tangible incentives and utility of welfare-ism.

Officers, lawyers and outdated legal education cannot perform appraisal

criteria of judicial policy. Financial as well as moral corruption (use of authority for
personal gains) and absence of jury system has transformed the judicial branch into a
semi executive organ, this semi- executive transitional tilt had turned dispensation of
justice into a politics of judicial bureaucracy.

Under such “execo- judicial attitude,” the major cause of an inefficient

judicial system is a “costly and orthodox nexuses among procedural oriented judges
under strict legal positivism, well connected lawyers and influential litigants. Such
nexuses and vicious triangle had transformed the basic unit of dispensation of
justice; the office of civil judge cum judicial magistrate into a most vulnerable forum
of judicial business in Pakistan. Unnecessary adjournments, undue review and
revision appeals, lawyer’s strikes on petty issues along with coercive bar politics,
delaying tactics to prolong unjustified status quo through temporary injunctions and
noncompliance by prosecution branch engender this vulnerability.
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Regrettably, it remained unnoticed in the National Judicial Policy of Pakistan

(NJP). Consequently, it lacks indigenous support and identification of actual
stakeholders and target groups. It is mainly reactive, established on conservative
pattern of routinization so it has nothing to do with capacity building of the judicial
system because the goals and objectives of NJP are mainly focusing on the
elimination of corruption, occurrence of pendency, the issue of backlogs and
inefficiency of the prosecution branch. However, it is not dealing with the time
consuming procedural difficulties, with an absolute ignorance of indigenous socio-
political and economic system. Thus systematic attempts to inject foreign concepts
and philosophies in an outdated traditional judicial system would be a futile exercise.

Therefore, ADR as well as Public Interest Litigation can remove the legal
antinomies between status quo and change. The former is known in different
jurisdiction of the world as under; Admission before Court, Alternative Sentencing,
Arbitration, Arbitration Association, Bottom up Reconciliation, Case Administration,
Case Management, Collaborative Litigation, Community Justice, Conciliation,
Community Owned Justice Through Monitoring and Evaluation, Confession,
Conflict Resolution, Court Connected ADR ,Court Connected Mediation, Court
Integrated Alternate Resolution, Court Referral ,Court Related ADR, Dispute
Avoidance, Early Dispute Resolution, Early Resolution of Disputes, Facilitative
Judging, Judicial Confession, Judicial Dispute Resolution (JDR), Jirga, Lok Adalat,
Mediation, Mediation Association, Mini Trial, Negotiation, Neutral Evaluation, Non-
Adversarial Litigation, Ombudsman, Online Conflict Resolution, Online Dispute
Resolution, Private Dispute Resolution, Probation, Participative Justice, Punchaiet,
Pre Litigation Conciliation and Settlement Restorative Justice, Third Party
Resolution, Top Down Mediation. Such consensus based adjudication in
international law with regards to trade dispute. Moreover, it is important to mention
here some of the ADR related legislations prevailing in Pakistan and other common
law countries. These are as follows;

 Arbitration Act 1940, Pakistan,

 The Conciliation Courts Ordinance 1961.
 Civil Procedure Code 1908, Section 89-A,
 Customs Act 1969,
 Section 195-C, Income Tax Ordinance 2001,
 Section 134-A,
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 Federal Excise Act 2005,

 Section 38, Sales Tax Act 1990,
 Section 47-A, Pakistan Muslim Family Law Ordinance 1962,
 The Small Claims and Minor Offences Courts Ordinance of 2002,
 Alternative Dispute Resolution Act of 1998, USA,
 Mediation Act 1997, Australia,
 The Truth and Reconciliation Commission Act 2000,
 The Truth, Justice and Reconciliation Bill, 2008 Kenya,
 Permanent Lok Adalat of India Rules, 2003,
 Singapore International Arbitration Centre “SIAC.”

8. Developing ADR in Pakistan

Majority of legal experts believe ADR, if developed properly and covered by

proper legal rules and provisions, could prove to be a better substitute of the existing
judicial system. The existing judicial system engage the parties in endless litigation
involving multiple formalities; too much cost and time consuming so much so that
oftentimes the actual litigants die before the settlement of their dispute through
Courts. It is time costly as well as mentally exhausting especially in developing
countries like Pakistan, India etc who have followed the footsteps of other Judicial
Systems which are not conformity to the culture and nature of its own people.

As has been discussed above, the term ADR consists of three main
subcategories, which are Mediation, Arbitration and Reconciliation. These
alternative means of administration of justice has a potential to increase the culture
of tolerance in the overall simmering society of Pakistan. This vibrant concept is
called Restorative Justice. ADR is not limited to civil felonies but it also has a
potential to cater criminology and victimology to reduce socio-political frictions
from the civil society. The community owned bottom up approach of mediation and
reconciliation is an innovative approach, where judges ought to perform not only as a
facilitator but they are also bound to monitor the whole process of voluntary
Reconciliation through monitoring and evaluation techniques of PRA approach
(Participatory Rural Appraisal). Institutionalization of the traditional Punchayat
system through the induction of young lawyers under the constant monitoring of
existing judicial officers is a pragmatic approach to integrate ADR in the mainstream
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legal System of Pakistan. This contextual and behavioural legal approach are a viable
solution of a vital issue of delays and backlog mentioned in NJP2009/2010.
Nevertheless, through a proactive Restorative Judicial Approach, Lower courts can
even reduce the caseload of high courts and Apex Courts, which comes through
direct constitutional jurisdiction under the constitution of Pakistan 1973.

Experts believe that the legal system in Pakistan has not earned yet a positive
distinction for handling properly and timely the adjudication of all sorts of cases that
come before it. Thus, some cases are not blessed with verdicts sometimes even in the
lifetime of an accuser and he or she may not live to see the verdict let alone get any
benefit from it. Reforms of the legal system are underway and the same could lead to
appreciable reduction in the backlog of unresolved cases after a period of some
years. As a result of Legislative initiatives, amendments in the Constitution and
other Civil laws have taken place.

Alternative dispute resolution can mitigate sufferings of poor litigants as

it is cheaper and speedier than the existing legal system. Increasing expenses of
litigation, delay in disposal of cases and huge backlogs in the existing legal
system have shaken people’s confidence in the judiciary. Against this backdrop
we cannot but ponder about a device like the ADR, which is potentially useful
for reducing the backlogs and delay in some cases of our courts. We recognize
traditional, informal and indigenous forms of dispute resolution, like
Punchayat, there were handicaps such as dominance of social elite, lack of legal
awareness, superstitions and biased mindset. The purpose of the ADR was not
to substitute consensual disposal for adversarial disposal or to abolish informal
mediation outside courts but to make it part and parcel of the legal system,
preserving the trial court’s statutory authority and jurisdiction to try the case
should the ADR fail.

9. Legal Modes of ADR in Pakistan

There are a number of ways to resolve a dispute outside the court; however,
more commonly practiced are Arbitration, Reconciliation and Mediation.
Henceforth, such a nonconventional, consensual dispute resolution mechanism is
further divided into three parts, covering each of the above mentioned concepts. As
for as, the arbitration is concerned, it is formally practiced in Pakistan. It is quasi-
judicial process, in which an arbitrator, nominated by the parties, or an umpire,
nominated by the arbitrators thereto, gives an award to dispose of the dispute. This
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award, however, is to be submitted in the court to be declared as “rule of court‟, but

the party against whom the award is given can always object before the court prior to
such declaration. Conciliation, also being a quasi-judicial procedure, is being
practiced in Pakistan up to a certain level. In spite of the already existing legislation
in this regard i.e. the Reconciliation Courts Ordinance 1961 that provides for the
resolution of minor civil and criminal offences through the reconciliation, the use of
this tool is not optimal. Finally, the mediation which has not been exclusively
provided by some legislation, however, section 89-A of the Civil Procedure Code
1908, inserted through an amendment in 2002, substantively provides to avail such a
tool for an expeditious disposal. This is a fact that due to arguable reasons mediation
still needs to be realized and promoted the judges and lawyers equally.

10. Rationale of ADR in the Tribal Area of FATA/PATA for Sustainable Peace

The Hobbesian concept of state as political community is compatible as such

with the Austin’s notion of legal positivism where law is a “command of sovereign”.
Such vertical model with permanent structures of legislature, executive and judiciary
works on the legal premise of certainty and obligation to obedience. In this
conventional scheme of law, rule contains, prescriptions, authorization and sanctions,
the last element deals with the nonconformists to pay a rational price in the case of
disobedience. However, such models seem not practical in the case of a horizontal
structure of a tribal society or during a transitional security paradigm like in the tribal
belt of the Federally Administered Tribal Area of Pakistan (FATA), where court
structure is not present as such. Scholars believe it is impossible to organize
segmentary lineage systems in terms of opinions [binding judicial decisions], courts
and police. For a national integration of such area into the mainstream political
community, he suggests a concept of “Jural community” for an effective social
control, based upon consensual justice derive from customs. It mainly deals with
arbitration, mediation and reconciliation (core elements of ADR) through an
authoritative body of elders, which derives its powers from traditions and natural
justice. In the contemporary wave of law and order crisis and internal disturbance
which prevails in the FATA and its adjacent areas, supra concept of journal
community would be an effective tool to bring a sustainable peace.

11. Practical Measures for ADR

ADR covers a multitude of options including, but not limited to, mediation,
neutral case evaluation, judicial settlement conferences, and Collaborative Law. We
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should actively embrace advances in technology and use ordinary language to help
the public understand the law and better access justice. E-learning could be a
valuable vehicle for explaining legal information and options for resolving disputes
through ADR to the public. Electronic submissions to courts could lessen the
geographical hindrance for rural or elderly residents. Simplified forms and
procedures could allow more residents access to our court system by aiding those
with low literacy and language skills. Video-conferencing may also be an option in
mediation. As lawyers, we should provide pro bono work in our fields of expertise,
targeting those who cannot afford an attorney. We should also encourage the next
generation of lawyers to undertake this civic duty. With our support and supervision,
we could expand our law school clinics and partner with non-profit organizations
and community mediation centers to reach a larger percent of the population.
Teaching dispute resolution skills to students within the law school curriculum,
especially early in their studies, will provide them with the opportunity to gain skills
and experience while providing service to lowincome clients through supervised
mediation programs. Justice not only stems from equal access to our legal services
but also access to fair outcomes in disputes. Mediation offers quicker and more
amicable results than typical litigation. By expanding our support of mediation and
other ADR solutions, we can reach more Virginians. Our everyday actions as
attorneys with clients can help distil any fears of the legal system, introduce all of the
available alternatives, and help make justice more accessible economically and
intellectually to all.

A major focus should be on training for developing professional

mediators and sensitizing judges, lawyers, policymakers, litigants and the
masses. It is stressed on creation of a regular corps of trained and efficient
mediators or neutrals, relying on whom judges or parties in a dispute can
comfortably go for consensual process of the ADR methods. The
recommendations include networking and sharing at national, regional and
international level, developing curricula for incorporating the ADR in
education and continued monitoring, evaluation and improvement of ADR
processes in use.

Alternative facility in Pakistan is yet to take a meaningful uplift. But this

newly enacted provisions facilitating the ADR system in our justice delivery
process is highly appreciable which will open a new horizon in our legal
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firmament. For meaningful expansion of ADR in Pakistan legal resource has to

be developed among the rural poor by providing them with alternative lawyers
and judge. The next step would be for the society to come forward to accept
change of traditional legal procedure. Only reformative thinking, new values,
new projection and positive outlook with determined action can achieve this.

The proposed reforms to Civil Justice have been under discussion for
some years and usage of ADR have had a significant influence on the way in
which litigation is conducted in Pakistan, in the sense that courts have tended to
anticipate the changes to some extent, or to interpret existing rules in a way
which is compatible with ADR philosophy. Nevertheless when the new
legislation has come into force, radical changes are needed in the way in which
the courts and lawyers operate.

ADR could be made more effective if developed properly particularly in a

developing country like Pakistan by opting/acting in following manner:-

 Providing not only alternative dispute resolution but also appropriate

dispute resolution, which means that the process that matches the needs of
the parties and the kind of dispute at hand.
 Creating awareness among the general public through public awareness
campaigns using various means and taking all necessary measures in this
regard.
 Role of lawyers/advocates becomes extremely crucial for it is them who
could properly guide the parties to opt for ADR by explaining the
procedure and benefits of the ADR.
 Judges and legislators do also have a role to play. Providing legal rules
and policies which promote settlements of disputes through ADR and
directing, persuading and driving the litigants to the path of alternative
dispute settlement could result in better access to justice.
 Making ADR a less stressful, less contentious, and less competitive
procedure and better results for the parties.
 Providing the citizens with more affordable and faster ways of solving
their cases than litigation. Especially, small claim mediation and
neighbourhood justice centres could contribute towards this aim and
would therefore also contribute to access to justice.
 Ensuring the element of pressurizing the parties into settlement is
addressed by providing appropriate means and ways could lead to better
and maximum access to “first class justice”.
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 Making ADR more effective, extensive, and pro-active, coordination is

needed among different agencies.
 Spreading the success story of ADR.
 Encouraging NGOs to become involved in ADR.
 Involving the Bar Associations in ADR.
 Providing training for mediators.
 Matching Government and NGO efforts.

12. Conclusion

ADR, indubitably, is the best and most effective solution to reduce the
Himalayan pendency in various courts of our country as it is more effective and it
provides an amicable solution and both parties are in win – win position which
brings about a harmonious relationship between both the parties unlike in the
conventional courts, thus it is permanent solution to any dispute, as it don’t lead to
appeal or revision, and hence reducing the burden of appellate courts as well. It also
saves valuable time and energy of the courts which can be utilized erstwhile in other
matters pending before court and it renders justice on time (Justice delayed is justice
denied, but ADR saves time and timely judgment is possible).
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References:

Marshall Procedural requirements OS01 Alternative Dispute Resolution Process

MPR 2010.1

Alternative Dispute Resolution Practices' Guide, Technical Publication Series

(March 1998)
Meek,S 1996, Alternative Dispute Resolution, Lawyers & Judges Publishing
Company Inc, Tucson.

Folberg, J, 2005, Resolving Disputes: Theory, Practice, and Law, Aspen Publishers,
New York

Meek,S 1996, Alternative Dispute Resolution, Lawyers & Judges Publishing

Company Inc, Tucson

Sitanna v. Viranna; AIR 1934 SC 105.