The Indian Contract Act and Specific Relief Act give many remedies for breach of
contract. One such remedy is 'Quantum Meruit'. This Latin phrase means 'as much
as he deserved'. This remedy aims at providing the plaintiff their due for
the services they have rendered. This is an equitable remedy which aims to
restore and compensate the plaintiff for providing her services in the case when
no price has been agreed upon.
Another similar concept is that of 'Quantum Valebant' which literally means 'as
much as they were worth' this is a remedy similar to Quantum Meruit; it aims
at providing the plaintiff a reasonable price for the goods they have sold. This
is the only difference between the two, while Quantum Meruit is a remedy for
providing the reasonable value of services rendered by the plaintiff, Quantum
Valebant is for the goods sold or delivered.
According to Anson's Law of Contracts:
"These restitutionary remedies may be available not only to an innocent party
but also, in certain situations, to a contract-breaker. These remedies may also
be available in respect of money paid or non-monetary benefits rendered under
other ineffective agreements including those that are void, tainted by
illegality, discharged for frustration, or too uncertain to amount to
This doctrine is believed to be developed in the seventeenth century by the
Court of Chancery in England. The inflexibility and arduous nature of the Common
Law courts drove more and more people to the Court of Chancery as it was
flexible in its approach and it ensured an 'equitable' remedy to the aggrieved.
They developed the principle of Quantum Meruit along with other equitable
The earliest reported cases under this doctrine concerned people who
were engaged in the so-called trades of common-calling, for example, tailors,
innkeepers, etc. The principle evolved over time as more service industries came
up, and has now come into wide-spread use.
In India, a claim under Quantum Meruit is allowed by section 70 of the Indian
Contract Act that says that when a person 'lawfully' does anything for someone
and does so 'non-gratuitously', and the latter enjoys the benefit of it, he (the
latter) is bound to compensate the former. This section of the Indian Contract
Act falls under Chapter V titled 'Of Certain Relations Resembling Those Created
This means that the principal deals with cases wherein a contract
is not explicitly made rather when there is a 'Quasi-Contract'. If there was no
contract in place or if there was one, the price of rendering the services was
not already agreed upon, the court can compensate the aggrieved party and
compensate for the lawful services they have rendered.
This principle has evolved in India by through judicial interpretations in
different cases. Cases like State of Madras v. Gannon Dunkerley & Co. (Madras)
Ltd., Alopi Parshad & Sons Ltd. v. The Union of India and Puran Lal Sah v.
State Of U.P are a few among many others that clarify the principle of
Quantum Meruit and throw some light upon how this principle has to be applied in
This is a useful remedy in situations when a person has been unjustly benefited
by the acts of the plaintiff. This remedy can ensure justice and fairness in
situations which do not have an adequate legal remedy because there are
limitations to every law.
Quantum Meruit: Meaning
When a Contract is breached, one can file a suit and claim compensation for the
same but this is only possible when we are able to tick mark all the essentials
that make up a valid contract. Things like free consent, lawful object and
consideration are some of these essentials without which a contract can't be
enforced in the court. But in some situations, although a valid contract did not
exist, one party may face some loss. To ensure justice and equity, the common
law has some 'equitable remedies' which are given by the courts when either a
legal remedy is unavailable or if available, is inadequate.
One such remedy is based on the principle of Quantum Meruit. The term literally
means as much as one deserves. This is a restitutionary award which is used to
pay to the aggrieved party their due for rendering their services. In the words
of Judy B. Sloan, "It is very much an alternative "shadow" system. A law student
who first encounters it in Contracts I often feels like the biology student who
is told that, in addition to a circulatory system, there is also a lymphatic
system hidden within the circulatory system."
In a claim of quantum meruit, the plaintiff does not seek a precise sum of
money, nor a sum representing the general damages incurred by the plaintiff as a
consequence of some unjust act on the part of the defendant, but a sum which
will provide the plaintiff, the value of what the plaintiff has done for the
defendant, usually calculated in terms of the market price or value of those
History of the principle
In the thirteenth century, there existed a writ of 'trespass'. It can be called
a rough equivalent of modern day tort. Through this writ a defendant was called
to come and tell why he committed wrong. But this general trespass proved
insufficient due to rigid requisites and so, 'trespass on case' developed. This
helped in including cases with similar factual circumstances to be brought to
The trespass on case established some idea of a duty to be present that
had been breached. Initially, this duty was based on the law, customs or the
relationship between the parties but over the course of time, this duty came
from 'assumpsit' which meant that a person had assumed responsibility to do
something for someone else and had done that badly. In this regard there are two
cases which help illustrate.
In the Humber Ferryman Case, the plaintiff had
given his mare to the defendant to be taken across a river the defendant's
ferry. But the defendant overloaded the boat so much that it overturned and
plaintiff's mare drowned. Going by the normal procedure, it was merely a case of
trespass but the plaintiff alleged that the defendant had assumed responsibility
for damage. Similarly, in Waldon v Marshal
, the plaintiff had given the
horse to the defendant to cure it of its ailments but unfortunately, the horse
The plaintiff alleged that the defendant was negligent and as a result of
this the horse had died. The death of the horse (chattel of the plaintiff) was
the basis for constituting a writ of trespass but the undertaking by the
defendant formed the assumpsit part here.
These cases dealt with 'misfeasance' that is when someone performed an action in
a wrong manner. In cases of 'nonfeasance' the common law courts were skeptic to
allow the writ of trespass because these cases were thought to be under covenant
only. Hence, for many years, a person did not have any remedy for breach of
promises that were made to do something later on in the future.
With the passage of time, the courts felt the need to expand their jurisdiction
in the matters of nonfeasance. Thus, they tried to expand assumpsit to include
nonfeasance and thus, inflicted a duty on the people who were engaged in common
businesses such as tailors, innkeepers, barbers, etc. An action could be brought
against these persons if it was proved that they have deceived the plaintiff by
either rendering their services unskillfully or not performing what was asked of
them. This helped include nonfeasance in the remedy of assumpsit but this was
still based on the requirement of deceit, i.e. deceit had to be present for the
action to succeed.
In yet another attempt to expand their jurisdiction, the common law courts tried
to enforce debts wherein there had been a promise to pay, through assumpsit.
This came to be known as Indebitatus Assumpsit. This originated around the
sixteenth century. In 1532, in Pickering v Thoroughgood, the court held that
in such cases the plaintiff can elect to choose between indebitatus assumpsit
and debt. During the course of the century, indebitatus assumpsit was used
extensively. Courts even allowed this remedy where there was no promise to pay.
But, the upper courts would reverse such decisions because they feared that if
this remedy was used so much, it would negate the very reason for the existence
of the writ of debt.
This stance of the courts changed in 1602 with Slade's Case. Slade's Case
allowed an action of indebitatus assumpsit for cases wherein there was not a
promise to pay the debt. The court was of the opinion that whenever there is a
debt, a promise to repay the debt is implied. Because this remedy was
comparatively easier than debt, it soon gained popularity. But not all problems
were solved by this remedy.
Although this remedy assumed an implied promise to
pay the debt, it still required to prove the existence of the actual debt to be
able to claim remedy. At this point, the doctrine of Quantum Meruit began to
come in picture. After Slade's case, courts began assuming an undertaking or
promise in the circumstances where they weren't explicitly mentioned. This
concept was first used in cases concerning trades of common-calling like
innkeepers, tailors, etc.
The court assumed that they have some obligation to
serve their customers and the customers on their part had the duty to pay for
their goods and services. In Warbrook v Griffin
, 1609, an innkeeper was
allowed to imply a promise of the guest to repay the reasonable amount of the
services that had been provided to him. Many other cases followed this and
circumstances where there is no agreement as to what would be the compensation
started getting redressed through assumpsit. In the late seventeenth century,
the courts eased the need of proof of debt for indebitatus assumpsit and now,
actions in quantum meruit could also be brought under it.
Following Slade's Case
, Quantum Meruit could also brought in the contracts
implied in law (quasi-contracts). Thus, in Bonnel v Foulk, 1657, the court
allowed the plaintiff to recover the money that he had mistakenly paid to the
defendant through an action of indebitatus assumpsit.
The problem with these
kinds of transactions was that they were frequently confused with contracts
implied in fact. Lord Mansfield explained these new developments in terms of
their restitutionary nature and found a basis for implied-in-law contracts in
Roman law: "If the defendant be under an obligation, from the ties of natural
justice, to refund; the law implies a debt, and gives this action, founded in
the equity of the plaintiff's case, as it were upon a contract ('quasi ex
contractu,' as the Roman law expresses it).
Contractual Quantum Meruit
A quantum meruit claim can be contractual as well as restitutionary . We
can understand the distinction between these connotations by looking at the
following foreign cases:
In William Lacey (Hounslow) Ltd v. Davis, the plaintiffs rendered services
to the defendant at the latter's request in anticipation of a building contract
that failed to materialize. When the plaintiffs sued for payment for the
services, the defendant argued that it was the common expectation of the parties
that a contract would be entered into between them and that the plaintiffs'
services would be rewarded by the profits of the contract.
The defendant denied
that in the circumstances there was any implied promise to pay for the services
in issue. The defendant's argument was that any quantum meruit claim was
necessarily contractual, and any such claim was negated by the fact that the
parties had an express contract in mind thereby making it impossible to imply
any other, contradictory contract.
This argument was rejected. Instead the court
explained that quantum meruit, though contractual in origin, had given rise to
another form of action founded upon what was known, in 1957 when the case was
being determined, as quasi contract. In such quasi-contractual instances of the
application of quantum meruit the court looked at the facts and ascertained from
them whether or not a promise to pay should be implied, irrespective of the
actual views or intentions of the parties at the time when the work was done and
the services rendered.
The case of Burns Fry Ltd. v. Khurana involved both contractual and
restitutionary claims by the plaintiffs based upon their acts as agents for the
defendant in the sale of a business. An agreed fee was payable upon the closing
of the transaction. After the plaintiffs had found a purchaser willing to pay
approximately the price asked for the business by the defendant, the latter
changed his mind and decided not to sell. Krever J. rejected both claims. The
defendant had acted in good faith and was not in breach of any implied term of
Nor was the alternative of restitution, i.e. quasi-contract,
applicable. The nature of the contract was such that the plaintiffs had taken
the risk of not being paid if there was no sale and no substantial benefit had
been acquired by the plaintiff.
It can be seen from these cases that the basis on which a claim of quantum
meruit can be brought up and can get success is different when it is contractual
and different when it is restitutionary.
The Indian Contract Act and Quantum Meruit
The Indian Contract Act has two sections which are usually used to bring about
an action based on Quantum Meruit. Sections 65 and 70 have been used to enforce
claims of quantum meruit.
This section deals with the "Obligation of person who has received advantage
under void agreement, or contract that has become void". It says that any person
who has received benefit from an agreement that was void or a contract that has
become void is bound to restore it back or pay the compensation to the person
from whom such benefit was received. Quantum Meruit is granted under this
section on the basis of the principle of restitution of giving relief. According
to Pollock and Mulla, "when the contract is invalid under a statute, the refund
of benefit can be claimed either under section 65 or on the principle of Quantum
Let us understand this section with an example, if A sells his cell phone to B
and takes money from him not knowing that the phone has been stolen, he will
have to return the money back to B. if he doesn't he can be sued for claims of
"The Supreme Court observed in State of Madras v Gannon Dunkerley & Co. that a
claim for quantum meruit is a claim for damages of a breach of contract." In
other subsequent cases, the Supreme Court laid down requirements for this
remedy. In Puran Lal Shah v State of U.P. the court observed, "The original
contract must be so discharged by the opposite party that the plaintiff is
entitled to treat himself as free from the obligation of further performance and
he must have elected to do so.
The remedy is not available to the party who
breaks the contract even though he might have partly performed it. The remedy is restitutory; it is a recompense for the value of the work done by the plaintiff
in order to restore him to the position which he would have been in if the
contract had never been entered into. In this respect it is different from a
claim for damages which is a compensatory remedy.
The court accordingly did not
allow the claim of a contractor for extra payment on the ground that he had to
procure the raw material from a longer distance than that represented in the
In Indu Mehta v State of Uttar Pradesh
 it was held that the amount to be
given can be decided based on the price agreed. It may also be calculated on the
basis of the prevailing market rate if a price hasn't been agreed upon.
This section lays down the "Obligation of person enjoying benefit of
non-gratuitous act." To be very general, a gratuitous act is done for free that
is the person doing such an act doesn't expect anything in return. On the other
hand a non-gratuitous act is the opposite. In such matters the person doesn't
intend to do the act for free. A person who has benefitted from a non-gratuitous
act has received unjust benefit on the stake of the person who had done the
no-gratuitous act. Hence, the court seeks to restore the person of whatever she
This section binds the person who has been unjustly benefitted to repay the
plaintiff for the services or goods he has supplied. To understand this section
let us take an example, A had to do research for B for Rs. 1000 and send him the
research paper over email. He accidently sends it to C who uses A's research and
benefits from it. Now, he will have to compensate A because he was unjustly
benefitted from A's services. If he doesn't, a claim of quantum meruit can be
brought against him.
If in the contract, no price has been agreed upon, then the person who has been
unjustly benefitted has to compensate the reasonable sum for the services
rendered and goods delivered. But if there wasn't a contract in place, the
person will have to again pay a reasonable price for the services and goods from
which he has benefitted. In Krishna Menon v Cochin Devaswom Board  it was
held that "where the work under the contract was executed in a defective manner,
the breach going to the root of the contract, but the defective work was enjoyed
without protest, the contractor was entitled to payment for the defective work
on the principles of quantum meruit."
In some cases it was held that "when a contractor is to handle more cargo than
what was given in the contract and he incurs additional expenses to handle it,
he was entitled to payment for the additional expenses on the similar
Evolution of the principle through Judicial Interpretations
In this part, we will try to understand the how this principle has evolved in
India through the years and how have the courts interpreted it in different
cases. This will help us decide the scope of Quantum Meruit in India.
Moselle Solomon v Martin & Co.
Facts: the company Martin & Co had received an order for steel work by Mr.
Solomon. They sued Mr. Solomon for the price of the goods and brought a decree
against him which wasn't executed. Hence, they discovered that Mr. Solomon was
the trustee of half the shares and the other half was owned by his daughter Miss
Moselle Solomon. The company sued Mr. Solomon as well as his daughter. They said
that Mr. Solomon acted as an agent for his daughter.
Decision: the two judges Lord William J. and Jack J had a split verdict. Lord
William observed that "the remedy provided by Section 70 is not dependent upon
the law relating to the liabilities of principal and agent. It is an independent
remedy, which is based upon a different cause of action, namely, upon whether a
person has lawfully done anything for another or has delivered anything to him
not intending to do so gratuitously, and such other person has enjoyed the
benefit thereof. If so, he must either make compensation in respect of, or
restore the thing so done or delivered."
On the other hand Lord Jack held that "where there is an express contract,
Section 70 has no application, as shown by the heading of Chapter V of the Act,
in which the section finds a place."
This judgment observed that this remedy can be used only when an express
contract is not in place, that is, it can be availed in cases of
quasi-contracts. This seems a bit problematic as there maybe situations when
there does exist an express contract but no price or damages could have been
agreed upon in the contract for when there is a breach.
Alopi Parshad and Sons Ltd. v Union of India
Facts: Alopi Prashad and Sons had entered into a contract with the Government of
India to deliver ghee to the Army Officers at an agreed price. During the World
War II the contract was mutually changed and the price was reduced. After some
time the company demanded an increase in the prices. The government assured them
that this demand will be entertained. On this assurance they continued to supply
the ghee. But the assurance was never realized.
Decision: in this case the court held that "Compensation under quantum meruit is
awarded for work done or services rendered, when the price thereof is not fixed
by a contract. For work done or services rendered pursuant to the terms of a
contract, compensation quantum meruit cannot be awarded where the contract
provides for the consideration payable in that behalf. Quantum meruit is but
reasonable compensation awarded on implication of a contract to remunerate, and
an express stipulation governing the relations between the parties under a
contract, cannot be displaced by assuming that the stipulation is not
In this case, the court was right in denying the claim because, when there
already exists a contract which lays down the amount to be paid, why a claim of
quantum meruit should be allowed. If such claims are allowed, it would render
the terms of the contract meaningless.
Mulamchand v State of M.P.
the plaintiff had bought the rights to procure forest produce like lac,
tendu leaves, etc. from the Malguzari jungles of Madhya Pradesh. These rights
were purchased by the plaintiff before this forest area came under the ambit of
the state government. After this, it was alleged that the deputy commissioner
had taken charge of the entire Malguzari area and had prevented the appellant to
enjoy the rights he had acquired. He auctioned the forest produce which was
covered under the right of the plaintiff.
The plaintiff could only procure tendu
leaves that too after depositing an additional sum. The plaintiff did deposit
the sum to save them from being sold off by the deputy commissioner. The
plaintiff demanded refund of this money as well as the money he had given
earlier to purchase the right for the other forest produce.
the court inter-alia held that, "if a claim for compensation is made
by one person against another under Section 70, it cannot be on the basis of any
subsisting contract between the parties but on a different kind of obligation."
The court basically observed that the claims under section 70 cannot be made
when there is an existing enforceable contract between the parties. It can be
claimed in cases of a quasi-contract.
Puran Lal Sah v State Of U.P. 
the plaintiff had been given the work of constructing a road in Nainital.
The contract said that the person was to construct the road at a rate less than
what was stipulated in a schedule issued by the government. But rates in the
schedule were based on the assumption of the availability of stone near
construction sites and in this case there was no stone available. So, the
plaintiff had to get stone from great distance. He alleged that he was given
assurance by the P.W.D. authorities that he'll get the money for the extra work
done. Also, while doing the work, there was a large rock in between which was
removed. The plaintiff claimed compensation for the extra work done but was not
given so by the authorities.
In this case the court shed light upon a few things regarding this
principle. First, it said that for a quantum meruit claim to succeed, it has to
be brought by the party who is not in default. The party that has broken the
contract cannot get the benefit of this claim. Also, the court explained the
difference between a claim for damages and a claim of quantum meruit. A claim
for damages seeks to put the plaintiff in a post-performance position that is in
such a position that the contract has been executed. While a claim for quantum
meruit is a claim that seeks to restore the position of the plaintiff. It is as
if the contract never existed.
These interpretations by the court have helped in getting to understand this
principle in itself and have given new facets to it. This has made it easy to
understand and clarified the confusion between damages and a claim of
restitution in Quantum Meruit.
Mahanagar Telephone Nigam Limited v Tata Communications (the MTNL case)
This is one of the newer cases which deal with an important aspect of Quantum
Meruit. In this case, the issue before the court was that of
there was a contract between the two parties of a purchase order. The
contract stipulated an amount that was to be given in case of a breach of the
contract. TATA failed to perform its part of the contract and thus, MTNL
suffered losses. MTNL deducted certain amount from the bills of TATA saying that
the money has been deducted for the losses suffered by them.
The question before the courts was that when there already exists a contract
which lays down the liquidated damages in case of a breach, can a claim of
quantum meruit be brought under section 70?
the court held that in cases where a contract already exists and lays
down the damages in case of a breach, a claim of quantum meruit under section 70
is not maintainable. A person is entitled only to the amount stipulated in the
main contract and any amount other than that has to be refunded.
This stance has been adopted by the court in older cases also. It is
understandable but, in many cases this can prove to be problematic because even
if there is an express contract and the prices have been agreed upon, a
situation may arise where a person has to do extra work or go out of their way
to get the work done. At such times, the person who has to done the work has
faced a loss and this has lead to the enrichment of the other party.
Conclusion and Suggestions
Quantum Meruit is a very useful remedy if it is used properly. This is a remedy
that ensures nobody gets an unfair or unjust benefit from the services rendered
by a person. It is one of the principle concepts of equity which helps in
restoring the loss that a party has suffered. It aims to give remedy to every
such person who has worked hard for something which he did not intend to do for
free and the benefit of that service has been taken up by someone else.
situations, to be fair, one has to be given compensation for his services. This
remedy developed in common law during the seventeenth century and has evolved
ever since. Through the years, it has seen various developments and has evolved
in different contexts. This remedy came to India with the British and has
developed in our Indian context. We looked at various cases in India which have
laid down what is quantum meruit.
The problem this paper tried to address is
whether the interpretations of this principle by the courts in India have been
able to ensure equitable justice or not. After analyzing certain judgments, we
can say that the courts have tried their best to give justice to the aggrieved
party and have tried to interpret these provisions in such a manner that they
are neither very rigid nor too flexible.
But it is important to point out here
that this principle hasn't been realized to its best yet. Indian courts have
maintained a stance that when there exists a contract, a claim in quantum meruit
cannot be constituted. But, as pointed out earlier, this can create problems in
cases where a party has to go out of their way to complete performance of their
side of the contract. If such extra-work isn't accounted for in the contract, it
will unfair if that party is not adequately compensated.
Although it can also be
looked at this way, this situation has encouraged people to draft contracts more
carefully and efficiently. But even a well-drafted contract can't always give a
fair and just remedy to an aggrieved party. Some suggestions which can help
enhance the ambit of the principle of Quantum Meruit in India are: the courts
should interpret these provisions in a way that they include contractual quantum
meruit as well; it would be better if all the condition that are requisite to
constitute a suit for compensation under Quantum Meruit are listed out and made
into a rule; Quantum Meruit should be given on the basis of the reasonable price
or value of any good or service that is prevalent in the market keeping in view
the circumstances of the case in hand.
For now, until the courts change this
stance of theirs, people can keep in mind at the time of making a contract to
keep the liquidated damages at par with what can be the damages if a suit for
quantum meruit is brought. Although this won't be able to solve all the
problems, for the time being, this can be done. Thus, we can conclude by saying
that quantum meruit is an interesting and useful remedy in law of contracts but
its scope needs to be widened through continuous work of the courts.
Blogs referred to:
- Beatson, J., Andrew S. Burrows, and John Cartwright. 2020. Anson's Law of Contract. 31st ed. London, England: Oxford University Press
- Pollock & Mulla (2018) The Indian Contract & Specific Relief Acts.15th ed. LexisNexis
- Singh, Avtar (2017). Law of Contract (12th ed.). Lucknow: Eastern Book Company
- Judy B. Sloan, Quantum Meruit: Residual Equity in Law, 42 DePaul L. Rev. 399 (1992)
Available at: https://via.library.depaul.edu/law-review/vol42/iss1/31
- G.H.L. Fridman, Quantum Meruit, Alberta Law Review Vol. 37(1) 1999, Available at: https://www.albertalawreview.com/index.php/ALR/article/view/1472/1461
- The Indian Contract Act, 1872 (Act no. 9 of 1872)
Websites referred to:
- Pratik Jain, India: Quantum Meruit, Mondaq, published on 14 January 2020
- Available at https://www.mondaq.com/india/contracts-and-commercial-law/881198/quantum-meruit
- (accessed on 2-11-2021)
(The Indian Contract Act, 1872)
- Black's Law Dictionary
- Anson's Law of Contract (31st edition, 2020), J. Beatson, A. Burrows, J. Cartwright
- 1959 SCR 379, AIR 1958 SC 560
- (1960) 2 SCR 793
- (1971) 3 SCR 469
- Judy B. Sloan, Quantum Meruit: Residual Equity in Law, 42 DePaul L. Rev. 399 (1992)
- G.H.L. Fridman, Quantum Meruit, Alberta Law Review Vol. 37(1) 1999
- Bukton v. Townsend, Y.B. 22 Lib. Ass., fo. 94, pl. 41 (K.B. 1348)
- Waldon v. Marshall, Y.B. 43 Edw. 3, fo. 33, pl. 38 (1369)
- (1532) 93 YB Sel Soc 4
- 76 Eng. Rep. 1072 (K.B. 1602)
- 123 Eng. Rep. 927 (C.P. 1609)
- 82 Eng. Rep. 1224 (K.B. 1657)
- Moses v. MacFerlan, 97 Eng. Rep. 676 (K.B. 1760) cited in Quantum Meruit: Residual Equity in Law by Judy B. Sloan
- J & J Penner Construction ltd v. Cringan (1994), 93 Man. R. (2d) 252 (Q.B.)
- Capital Construction & Foundation ltd. v. Cote (1993), 124 N.B.R. (2d) 204 (T.D.)
- [1957) I W.L.R. 932
- Ibid pg. 936
- (1985), 20 D.L.R. (4th) 245 (Ont. H.C.J.)
- Unlike the party which decided not to go through with the contract arranged by the agent in Alpha Trading ltd v. Dunnshaw-Patten ltd.,  Q.B. 290, on which see G.H.L. Fridman, The law of Agency, 7th ed. (London: Butterworths, 1996) at 197-98.
- As it would have been in Capital Construction & Foundation ltd. v. Cote (1993), 124 N.B.R. (2d) 204 (T.D.) [hereinafter Capital Construction], if the defendant had obtained anything of value from the work done by the plaintiffs, which was not the case.
- The Indian Contract Act by Avatar Singh
- (1971) 1 SCC 424
- Waldon v. Marshall, Y.B. 43 Edw. 3, fo. 33, pl. 38 (1369)., Avatar Singh
- AIR 1987 AII 309
- VR Subramanyam v. B Thayappa (1961) 3 SCR 663
- AIR 1963 Ker 181
- Pollock and Mulla Pg. 1056
- Food Corporation of India v Vikas Majdoor Kamdar Sahkari Mandli Ltd. 2007 AIR SCW 6999; NHPC Ltd. v Oriental Engineers, 2016 SCC OnLine Gau 60
- (1935) ILR 62 Cal 612
- AIR 1960 SC 588
- Supra note 24 pg. 809
- AIR 1968 SC 1218
- (1971) 3 SCR 469
- (2019) 5 SCC 341
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