The Sale of Goods Act, 1930 is an advanced piece of legislation given the
nature of the early 20th century. It has detailed provisions regarding different
types of sales, possessions by a rightful owner along with what comprises as
exceptions upon certain sale agreements where rightful ownership can be
Like any piece of legislation, it has to firm up its boots and embrace the 21st
century with new dimensions arising in the digital market and contract legal
aspects. Therefore, it becomes imperative to study how the principle of Nemo Dat
Quod Non Habet works under the Sale of Goods Act 1930 and how it should evolve
given the circumstances in the modern era.
Interpretation of Nemo Dat in Sale of Goods Act 1930
The Sale of Goods Act 1930 has had a revolutionary impact in the dealings of
buyers and sellers in the contractual state of affairs. It has enabled certain
rights and principles which help in protection of buyers and sellers in the
scenarios of disputes relating to possession, delivery and unpaid sellers. It
also includes problems for other solutions. The Act was made with a clear
provision in mind. Since the Indian Contract Act,1872 was proving to be
unsatisfactory for the meeting the community requirements at large, it was
decided that a separate act is necessary for meeting new mercantile
The principle of Nemo Dat Quod Non Habet plays a big role in the formation of
the underlying intention of Sale of Goods Act 1930. Upon translation, it can be
seen that the general meaning of this maxim is "no one gives what they do not
The rule of Nemo Dat is based on the idea that a free society can only exist if
property rights are strictly upheld. Individuals in a decentralized economy will
seek to maximise their wealth by increasing the market value of the real and
personal property they own.
Section 27 of the Sale of Goods Act,1930 codifies the Nemo Dat concept which
helps in protecting unwitting buyers. It is quoted as follows
"Subject to the provisions of this Act and of any other law for the time being
in force, where goods are sold by a person who is not the owner thereof and who
does not sell them under the authority or with the consent of the owner, the
buyer acquires no better title to the goods than the seller had, unless the
owner of the goods is by his conduct precluded from denying the seller's
authority to sell: Provided that, where a mercantile agent is, with the consent
of the owner, in possession of the goods or of a document of title to the goods,
any sale made by him, when acting in the ordinary course of business of a
mercantile agent, shall be as valid as if he were expressly authorised by the
owner of the goods to make the same; provided that the buyer acts in good faith
and has not at the time of the contract of sale notice that the seller has not
authority to sell."
Cases like Greenwood v. Bennett
, where the original owner of the
Jaguar car was given due importance of titleship rather than the person who
invested money in repairing the car is one of first examples of this principle
in force in real life. This also applies to life insurance policies as seen in
the case of Life Insurance Corporation vs United Bank of India Ltd.
What Are The Exceptions To Sale Of Goods Act 1930?
In the traditional sense, the section defines certain exceptions to the Nemo Dat
rule which is demarcated in many cases over the years:
Transfer of title by estoppel (Sec 27)  Estoppel refers to a situation in which a person or group of persons make
the other believe that certain setup existed due to the conduct or words
spoken by them. These people would later be disallowed from refuting that
the situation did not exist in the first stage.
One of the most famous cases relating to title by estoppel is Eastern
Distributors v. Goldring. In this case, Mr. Murphy, the third party,
owned a Bedford van. He was trying to get funding so he could purchase a
Chrysler. In order to achieve this goal, Mr. Murphy and Mr. Coker, a car
dealer, created a plan in which they would trick a hire-purchase business
into financing the purchase of the vehicles.
The dealer would then act as though they had purchased the van and were
offering it for hire-purchase to the owner. The defendant acquired the
vehicle because a hire-purchase firm purchased and leased it to Mr. Murphy.
This latter group legitimately needed a van, so they bought one. When Murphy
stopped making payments, the hire-purchase business tracked down the vehicle
and filed a conversion lawsuit against the defendant.
The Court of Appeal ruled that Mr. Murphy did not legally transfer ownership
of the vehicle to the defendant when he made the sale to them; rather, the
title was already in the name of the hire-purchase firm, the plaintiff. Mr.
Murphy surrendered up van title under the hire-purchase agreement. He was
just a bailee under the hire-purchase agreement, not a vendor.
In other words, if the real owner conveys through his actions or word
leading another to believe that the seller is a legitimate owner or has the
legitimacy to sell these goods, he cannot repudiate the seller's authority
afterwards. Estoppel arises either from an act or omission (but it should be
a legal obligation) or Negligence (but it should be in regard to the
An example for estoppel by act or omission is as follows:
B offered A to buy a car that A portrayed as his, but it belongs to C. C
said nothing despite knowing everything. When B sells the car to A, C has no
right to take it back, and A will acquire a valid title even if it doesn't
belong to B. In estoppel by negligence, A person's negligence in the
handling of his own affairs is not enough to produce an estoppels; the
negligence has to expanse to a disregard of his obligations towards the
person who is putting up the defence in order for it to work under this
Conventary Shepherd & Co v. Great Eastern Rly.Co and Shaw and Another v.
Metropolitan Police Commissioner are examples of estopped by negligence.
In the first case, The defendants were estopped from denying that the
commodities in the order were held for the assignor. Someone who circulates
such documents bears a duty to others who may receive them. The second case
held that the claimant clearly represented to the dealer that he should sell
the car, and thus would have been barred from claiming return of the car.
Sale By Mercantile Agent (Sec 27) The Sale of Goods Act 1930 defines a mercantile agent as one who has the
authorization to sell or consign things for the purpose of sale, buy goods,
or raise money on the security of goods in the ordinary course of
business. The agent has the authority to do away with the goods,
provided he has the authority from the original seller to do so. The problem
arises in the case in which he does not have any such power to do so.
For the correct application of this provision, there are some conditions
which must be fulfilled before it can be applied in a scenario:
In Folkes v. King, The claimant handed his vehicle to a broker
who guaranteed a minimum sale price of 575 pounds. However, the commercial
representative squandered the money by selling goods to the defendant for
140 pounds. When the seller filed suit, the court found in favour of the
buyer (the defendant).
- Seller must fulfil the conditions of being a mercantile agent as
mentioned duly in Sec.2(9) of the Sale of Goods Act 1930
- He should have the appropriate consent of the owner while retaining
the capacity of being a mercantile agent at the time of possession of
goods or title of documents from the owner to him.
- Any product sales made by a mercantile representative should be done
so in the normal course of business.
- The purchaser must have acquired the items in good faith, without
knowledge that the Mercantile agent lacked authorisation to do so.
In the case of Hindustan Dorr Oliver Ltd. vs A.K. Menon and Ors., If
goods are left with the permission to sell, it doesn't matter if they are
left conditionally or not. So, the broker/agent must be in control of a
permission to sell. In these situations, even if the conditions aren't met
or the authority is overstepped, the provision to Section 27 of the Sale of
Goods Act would come into play, and a good title would be given to the
person who bought the item for value.
Sale by Joint Owner (Sec 28) This section follows an interesting usage of the principle of Nemo Dat Quod
Non Habet. In a case where one of the joint owners has the prior permission
of other owners to have the sole possession of the goods in question, then
the person who shall buy the aforementioned goods in good faith from him/her
obtains the title of the goods. In a situation where this provision had not
existed, the buyer would have been regarded as one of the co-owners rather
than the single titular owner.
If X and Y decides to give an almirah jointly owned by X, Y & Z to D, then D
shall become the owner of the goods. It is because of the excision of good
faith that a liberty to D has been given for this.
In B.R. Patil v. Tulsa Y. Sawkar It was decided that each
co-owner owns the property on behalf of the whole group. Because of this,
what one co-owner has, is treated as what the other co-owners have; as long
as the other co-owners know about it.
Sale By a Person in possession under a voidable contract (Sec 29) There are certain circumstances which are enlisted in Sec.19 of the
Indian Contract Act 1872 through which the contract becomes voidable at the
option of the party whose consent has been obtained through coercion, fraud,
misrepresentation or undue influence.
Sec 29 of Sale of Goods Act, 1930 accounts for the circumstances mentioned
in Sec.19 of Indian Contract Act 1872 and provides that if a person obtains
the possession of some goods under a voidable contract underlying section 19
or 19-A of the Contract Act and sells them before the contract is nullified,
the buyer acquires good title to them.
However, this certain section does not corroborate to void contracts or in
the instance where the vendor is completely titleless. Also, the contract
should not have been rescinded by the other party in this situation.
In the case of Neev Trading Co vs Patparganj, The assessee-respondent
were not a part of the fraud. There were clear conclusions that they bought
DEPB on the open market with the honest belief that it was real. They had
paid the full price, so they could use the benefit. Even though the DEPB was
later found to be made up and fake based on the BCER, the assessee
respondent could not be denied the benefits they were legally entitled to.
Furthermore, the Supreme Court has reaffirmed the stand on this topic
through the cases of Sneha Sales Corporation also.
Sale by the Seller in Possession (Sec 30) (1) This section comprehends the complexity in the condition wherein the bought
goods or transferred titles of documents are still in possession of the
seller (however the ownership is with buyer) and the seller further sells it
to pass the title to another; who buys it in good faith with no idea of the
preceding sale. In this state of affairs, the authorization passes on and
the new buyer has the supreme title of ownership of such deeds or goods. An
illustration of the same is mentioned below:
A sells a toy car to B but keeps it since B had gone to an outstation trip.
During that time, A found one of his close friends C and made the sale of
toy car to C. Now C being unaware of the transaction between A and B and
gets the title of the toy car directly from B to himself.
Sale by the Buyer in Possession (Sec 30) (2) Any sale, pledge, or other disposition of the goods by the purchaser, with
the seller's approval, would convey good title and without notice as to any
lien or other claim of the original seller in respect thereto, as provided
in this section.
- Resale by an unpaid seller (Sec 54) (3)
This section provides a compensatory remedy to an unpaid seller who has not
yet received any payment for the sale of the goods. He is given the consent
by law to withhold the transit of such goods through the right to lien or
resell them, provided that he gives a notice to the buyer. The new buyer
therefore acquires a fresh title to such goods or title of documents.
The notice here plays utmost importance in the favour of such seller since
he may lose his rights of claim in consonance with losses from the reselling
of goods or lose the benefits accrued from such sale. In the case of Balaji
Paper Agency vs Mysore Paper and Board Co., it was held that since the
plaintiffs did not issue any notice, they were not entitled to damages as
claimed in the suit; in view of the specific provisions contained of the
Sale of Goods Act.
Sale by Finder of Goods (Sec 169, Indian Contract Act) If the owner cannot be located after reasonable efforts have been made, or
if he refuses to pay the legitimate fees of the finder upon demand, the
finder may sell the items. Before the ownership may be passed, certain
points need to be kept in mind in the midst of selling.
- When the value of the item is at risk of being lost entirely or
- When the finder's legal fees will consume more than two-thirds of
the item's value.
- Sale by Pawnee- Sec 176, Indian Contract Act)
If the debt is not paid by the pawnor when it is due, the pawnee has the
option of suing the pawnor for the debt or selling the goods that were
pledged after giving the pawnor sufficient notice of the sale. This
provision applies if the pawnor makes a failure in the payment of the debt.
Is Market Overt Principle A Valid Exception Today?
Market overt is an English law principle that derives its origination from the
medieval times envisaging on the idea of rightful ownership of title of stolen
goods. Due to its closeted community nature of buying, the market overt
principle lays emphasize on moving traders who engaged in trading with local
buyers, didn't move much outside of city for buying all of their goods and had
transactions upon good faith.
These markets were marked with following age-old traditions and toll charges
upon buying and selling where applicable; it was held that the ownership of
stolen goods got transferred as soon as these toll charges were paid.
However, there were also certain exceptions under the market overt principle
too. One of this included the passing of title of the property or goods to the
crown. The principle doesn't hold much of its own in today's times and is
even seen as anachronic since countries like New Zealand have already abolished
it. The United Kingdom kept the principle in motion following the Sale of Goods
Act 1974(U.K) despite the Law Reform Committee's recommendation of its
After an amendment in 1994 to the sale of goods act, it was decided to do
away with market overt in Wales but countries like Hongkong and British Columbia
still do abide by it. Outside of London, a market overt place would be seen as
an open, public but legally constituted market. One reason for protecting
the real buyer without notice in a market overt could be that in the past, the
government encouraged the growth of fairs and markets overt that had a lot of
This could be why the common law said that all sales made in public places like
fairs and markets should be good not only between the people buying and selling,
but also with anyone else who has a right to the goods. If stolen goods ended up
in a market overt, the owner could go to shops or stalls that sold things like
his own, and since the goods had to be out in the open to be sold, he would be
able to see them and get them back.
Thus, it put an onus on the buyer to put the efforts to recover his goods back
from the market and in the event that his efforts fail to reach a desirable
result, the buyer took good title. It held a practicable approach to fulfil the
desire of an ever-increasing commercial open market.
In modern London, it's not particularly useful to limit a theory to the City of
London, which has few retail stores. Trade has transitioned from markets to
retail establishments nationwide. New marketplaces have been created that aren't
grant- or statute-based. Due to increased mobility, the assumption that the
genuine owner can find his items at the local market is absurd.
The principle of Nemo Dat Quod Non Habet has been embodied in the market overt
rule through the legislation of Hongkong which follows the principle duly
through the enactment of section 23 of the Hong Kong Sale of Goods
Ordinance. A famous case on the principle of Nemo Dat Quod Non Habet in Hong
Kong is R v. Tai Shing Jewellery Co. In this case, a jewellery company
bought some jewels which were part of a robbery by paying the full market
The seller was brought it in for the charge of robbery and the appellants
contended that the silver coins stolen be returned to them as they possess the
title. It was held that the person who purchases items from a stall or in the
usual manner is the only person who is protected by the market overt provision.
When a shop owner purchases items from customers in his or her own store, the
shop owner is not afforded any protection by the law. Thus, the act is meant for
serving the consumers in the form of consumer protection and not in the
interests of business buyers.
Rameshwar v. Tarasingh and Ors. held that the principle of market overt has
not been given due recognition in the legislature of India which is why we can't
give pronounced judgements based on it.
Is The Seller In Possession Exception Due For A Check Up?
The policy of allowing the seller from whom you have engaged in a trade to sell
those goods which should have been rightly in your possession but now in the
hands of the other is a bit abysmal. It simply accounts for the fact that
commerce is given a strict priority over the rule of Nemo Dat since the policy
of promotion of trade holds a more significant value at the seller's discretion.
The humble origin of this section can be traced to the judgment in the case
Johnson v. Credit Lyonnais
 which led to a huge hue and cry in commercial
sectors since the second sale of some dock warrants to an innocent buyer was
deemed to be ineffective.
Denning L.J famously quoted the following words in relation to transfer of
titles in the case of Bishopsgate Motor Finance Corp:
"In the development of our law, two principles have striven for mastery. The
first is for the protection of property: no one can give a better title than he
himself possesses. The second is the protection of commercial transactions: the
person who takes the transaction in good faith and for value without notice
should get a good title."
One of the main essentials of this exception relates to the fact that the seller
in question must continue to have due possession of goods after selling them. He
may not exercise possession in any other capacity other than a seller; a bailee
would also not constitute to be a valid capacity to hold for possession.
A New Zealand case on the same reaffirms the position that possession depends on
the capacity of the person who is selling rather than the mere act of selling.
In Mitchell v. Jones
 , it was held that when the original seller
regained possession of an already sold horse in the capacity of a bailee, he is
not authorized to resell the horse and thus the second buyer's claim to the
horse failed. The seller did not have possession in the relevant sense i.e., in
the capacity of a seller.
However, such decisions have been provided a due check-up by privy councils in
cases like Pacific Motor Auctions (Pty) Ltd v. Motor Credits (Hire Finance)
 wherein the logic of seller remaining in possession as a seller and
not in any altered capacity was disparaged. Further decisions by court of
appeals in cases like Worcester Works Finance Ltd v. Cooden Engg Co ltd
and City Fur Manufacturing Co ltd v. Fureenbond (Brokers) London Ltd
have affirmed to going away with this exception by concluding that, 'innocent
buyer should not suffer at any costs whatsoever provided the element of good
faith was present'.
In another recent case of Jsw Steel Ltd vs Delta Iron and Steel Co.Pvt.Ltd
there was a question on the title of goods which was not paid by a party but
some of the goods seized by the court receiver had been sold to the applicant.
Since the goods had already been sold to the applicant, the petitioner did not
have any rights on the said goods. The court took notice of the same under
Section 30 of the Sale of Goods Act, 1930.
In essence, the principal of Nemo Dat Quod Non Habet
is not followed
here. It can be seen that even though the seller may have possession but not
ownership, the circumstances of innocent buying vitiate the principal of NEMO
DAT QUOD NON HABET.
Is there a need to look at Estoppel principle from the view of Nemo Dat Quod Non
Estoppel affirms the transfer the ownership based on omission, act or negligence
of owner so as to constitute an affirmation to such transfer of goods. Nemo Dat
Quod Non Habet ensures that a defective title cannot be passed upon another if
the person doesn't hold a legitimate transferrable title.
In the case of S. Kanthimathy & S. Lakshmi v. The Woodlands Estates Ltd. Ors
the company petitions filed in this case relates to account of unauthorised
transfer of shares. The second respondent was the son of demised holder of
shares who had manipulated the handling of shares in such a way that TRTCL
shares were transmitted exclusively to his brothers that were contrary to the
provisions of the will of the father.
The daughter who was the fifth respondent in the case was aware of the disputes
among the children of the diseased prior to the purchase of the shares due to
communication through multiple letters between them. Since she knew about the
defective title in the case of shares and decided to go ahead with the decision,
she would not be called an innocent buyer which is why the court held that
section 27(1) does not apply here. Her actions were deemed to have estopped the
ongoing sale through her act.
The principle of Nemo Dat Quod Non Habet applies here since the fifth respondent
was not deemed to be a bonafide purchaser of the shares and she couldn't get a
better title than the seller by the virtue of the section.
In the case of Mercantile Credit Co. Ltd. v. Hamblin
, a person
wanting to borrow money on the account of depositing her car as security was
frauded by a motor car dealer who was apparently her friend. The dealer then
went on to transfer ownership of car through incomplete hire purchase agreements
which showed the dealer as the rightful owner of the car. He then proceeded to
go for a double fraud by selling to the plaintiffs implying the car as his own
property which was kept to him as security only. He did this by sending duly
filled hire purchase papers and fled with the money he received.
The court concluded through the aforementioned facts that since the defendant
had not authorized the dealer in any way to represent her to the company as a
sanctioned authority to sell the car, there was no representation. Thus, the
exception laid down through the principle of Nemo Dat Quod Non Habet pertains
its effects here.
The estoppel principle affirms the position of the Nemo Dat principle in its
working which can be seen in multiple cases around the world and in India
itself. It takes into account the act, omission or negligence of the owner who
transfers the right of ownership and estopped from claiming it later; if the
Critical Analysis And Suggestions
Goods are an important aspect that are used every day in an individual's life.
Since transactions on these goods happen on a daily basis, it becomes imperative
to form a legislation that governs the buying and selling of such goods. Not
only should the concepts of buying and selling be present in a legislation but a
clear emphasis on rightful ownership and passing of titular rights should be
advocated by the markets. It was in this hope that the Sale of Goods Act 1930
was created in conjunction to the principle of Nemo Dat Quod Non Habet.
The Latin maxim exuded the idea of not allowing wrongful transfer of titleship
in case the person obtains goods by unlawful means. In the analysis of the act
with the underlying principle, it can be found that certain exceptions relating
to sale of goods under the maxim do not follow the principle as an innocent
buyer/seller may expect the market to do. But most of the times, the exceptions
do follow the same.
The market overt exception and estoppel exception bring their fair share of
meaning to the maxim and thoroughly allow the same to be followed in their
workings respectively. All the other exceptions like Joint owner and Sale by
Mercantile agent also follow the same coherence as found in the other two.
However, the exception of seller in possession gives due respect to the
commercial position in market rather than the innocence of either the buyer or
the seller and does not produce results consistent with the maxim.
It can also be observed that since market overt principle has either been
written off in many legislations or still in force with minimal changes
reflecting the outward look of 21st century. One such case is Hong Kong which
still holds on to the exception dearly. A major relook is needed in Hong Kong to
reform the overt exception in relating to new intangible goods too.
It is also suggested that the whole of Sale of Goods Act is predominantly biased
to tangible market-based goods and it should also include specific provisions
relating to new intangible software available freely over the Internet Market.
Goods like NFT pictures and other data driven goods that are present in a market
but don't come under the structure of cryptocurrency or share market should also
be included. 8th Law commission Report tried to add shares and other goods
under the scope of the act. But a new report is needed to analyse the addition
of more goods mentioned in this analysis.
Additionally, more rights of buyers and sellers should be introduced in the act
keeping in mind the diverse and dynamic nature of 21st century. In accordance to
Nemo Dat, it should be provided that all the exceptions should be re-written
with more situations accorded to the principle keeping in mind more focus on
goods currently in trend in the market. Lastly, the act should also include
e-commerce markets like Amazon and Flipkart since without an e-commerce section,
the cases pile up vaguely under IT acts rather than the act of selling
In respect of the findings in this paper and the suggestions determined in the
critical analysis section, it is of vital importance that changes be present in
the Sale of Goods Act 1930 and the principle of Nemo Dat Quod Non Habet is
injected more thoroughly into the act. Lastly, a new thought structure has to be
formulated to bring the legislation up to date and remove overburdening
principles which hamper efficient decision making.
- The Sale of Goods Act,1930, 46, No.3, Acts of Parliament,1930, (India)
- Suryansh Singh, Tracing the History of Sale of Goods Act 1930, Vol.3,
Nyaayshastra Law Review,1,1-14, (2022)
- ICLR UK, https://www.iclr.co.uk/knowledge/glossary/nemo-dat-quod-not-habet/,
(08th September 2022)
- Meusburger, Lorenzo U., The Proof Is in the Numbers: An Economic
Analysis of the English Rule of Nemo Dat, Vol.5, Cambridge Law Review,
- The Sale of Goods Act,1930, 27, No.3, Acts of Parliament,1930, (India)
- Greenwood v. Bennett, 208 Ala. 680, 95 So.159 (Ala. 1923)
- Life Insurance Corporation vs United Bank of India Ltd. AIR 1970 Cal 513
- Sale of Goods Act, 1930, 27, No.3, Acts of Parliament, 1930 (India).
- Legal Information Institute Cornell, Law School, https://www.law.cornell.edu/wex/estoppel,
(12TH September 2022)
- Eastern Distributors v. Goldring, (1967) 2 QB 600
- Conventary Shepherd & Co v. Great Eastern Rly.Co (1883) 11 QBD 776
- Shaw and Another v Metropolitan Police Commissioner  1 WLR 1332
- Sale of Goods Act, 1930, 27, No.3, Acts of Parliament, 1930 (India).
- Sale of Goods Act, 1930, 2(9), No.3, Acts of Parliament, 1930 (India).
- Folkes v King  1 KB 282
- Hindustan Dorr Oliver Ltd. vs A.K. Menon and Ors., 1994 80 CompCas 384
- Sale of Goods Act, 1930, 28, No.3, Acts of Parliament, 1930 (India)
- B.R. Patil v. Tulsa Y. Sawkar, (2022) LiveLaw (SC) 165
- Sale of Goods Act, 1930, 29, No.3, Acts of Parliament, 1930 (India)
- Indian Contract Act,1872, 19, No.9, Acts of Parliament,1872 (India)
- Supra Note 29
- Neev Trading Co v. Patparganj, Customs Appeal No. 53589 of 2018,
Customs, Excise & Service Tax Tribunal
- Collector of Customs, Bombay v. Sneha Sales Corporation, 2000 (121) ELT
- Sale of Goods Act, 1930, 30(1), No.3, Acts of Parliament, 1930 (India)
- Sale of Goods Act, 1930, 30(2), No.3, Acts of Parliament, 1930 (India)
- Sale of Goods Act, 1930, 54(3), No.3, Acts of Parliament, 1930 (India)
- Balaji Paper Agency v. Mysore Paper and Board Co., ILR 1991 KAR 2563
- Indian Contract Act,1872, 169, No.9, Acts of Parliament,1872 (India)
- Indian Contract Act,1872, 176, No.9, Acts of Parliament,1872 (India)
- Bryan A. Garner & Henry Campbell Black, Black's Law Dictionary,1122,
- Davenport, Brian, and Anthony Ross. Market Overt, vol. 2, International
Journal Of Cultural Property, 25, 25-46, (1993)
- Willion v. Berkley, (1561) 1 Plowden 223.
- Atiyah, The Sale Of Goods,306 (7th edition, 1985)
- Sale and Supply of Goods Act, 1994, Acts of Parliament,1994 (United
- Lee v. Bayes (1856) 18 CB 599
- Dora SS Neo, Application of English Law Act 1993: Sale of Goods and Nemo
Dat, SINGAPORE JOURNAL OF LEGAL STUDIES, 150 ,150-163, (1994).
- Sale of Goods Ordinance, 23, Cap 26, Hong Kong LegCo, 1896, (Hong Kong)
- R v. Tai Shing Jewellery Co  2 HKC 441
- Ji Lian Yap, Appraising the Market Overt Exception, Vol no. 3, Journal
Of International Commercial Law And Technology,254, 254-258, (2008)
- Rameshwar v. Tarasingh and Ors., AIR 1958 Raj 269
- Louise Merrett, The Importance of Delivery and Possession in The Passing
of Title, Vol no. 67, The Cambridge Law Journal,376, 376395. (2008)
- Johnson v. Credit Lyonnais, (1877) L.R 3 C.P.D 32
- Supra Note 51
- Bishopsgate Motor Finance Corp Ltd v Transport Brakes Ltd  1 KB
- Staffs Motor Guarantee Ltd v. British Wagon Co. Ltd, (1934) 2 KB 305
- Mitchell v. Jones, (1905) 24 N.Z.L.R. 932
- Pacific Motor Auctions (Pty) Ltd v. Motor Credits (Hire Finance) Ltd
1965 AC 867: (1965) 2 WLR 881 (PC)
- Worcester Works Finance Ltd v. Cooden Engg Co ltd (1972) 1 QB 210
- City Fur Manufacturing Co ltd v. Fureenbond (Brokers) London Ltd, (1937)
1 All ER 199
- Jsw Steel Ltd vs Delta Iron and Steel Co. Pvt.Ltd, Commercial Notice of
Motion (L) No. 2044 Of 2019 In Commercial Arbitration Petition (L) No. 948
Of 2019, Bombay High Court.
- Supra Note 34
- Oxford Reference, https://www.oxfordreference.com/view/10.1093/acref/9780198802525.001.0001/acref-9780198802525-e-2573,
(22nd September 2022)
- S. Kanthimathy & S. Lakshmi v. The Woodlands Estates Ltd. Ors, 2008 144
CompCas 830 CLB
- Mercantile Credit Co. Ltd. v. Hamblin  3 W.L.R. 798
- Law Commission, Sale of Goods Act 1930 (08, 1958) 7
Dat Quod Non-Habet
Award Winning Article Is Written By: Mr.Harjas Singh Gulati
Authentication No: NV233148801362-27-1122