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  • provisions of the United Provinces Control of Rent and Eviction Act, 1947. This; Act
  • section 15 of the United Provinces Control of Rent and Eviction Act
  • SECTION 76 GOVERNMENT OF INDIA ACT 1935
  • Provinces Control of Rent and Eviction Act
  • Provinces General Clauses Act, 1904,
  • 1947. Section 1(3) of this Act
  • sub-section (2A) of section 1,
  • section 5(2) of this Act
  • section 14. Section 15
  • section 1(3)
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Citation Codes
Equivalent Citations
citation codes
Case Number
Attorney(S)
Judges
Acts
  • provisions of the United Provinces Control of Rent and Eviction Act, 1947. This; Act
  • section 15 of the United Provinces Control of Rent and Eviction Act
  • SECTION 76 GOVERNMENT OF INDIA ACT 1935
  • Provinces Control of Rent and Eviction Act
  • Provinces General Clauses Act, 1904,
  • 1947. Section 1(3) of this Act
  • sub-section (2A) of section 1,
  • section 5(2) of this Act
  • section 14. Section 15
  • section 1(3)
Smart Summary

Structured Summary of the Opinion (B. Malik, C.J.)

Factual and Procedural Background

On 10 May 1947 a suit for ejectment was filed against the defendant in respect of a shop in the town of Raya. At the time the suit was instituted the United Provinces Control of Rent and Eviction Act, 1947 (the Act) had not been extended to the town of Raya by notification of the State Government.

The suit was contested; one ground raised was that the notice for ejectment was defective. On 21 July 1948 the trial court dismissed the suit because the ejectment notice was found not to be in accordance with law.

An appeal was filed to the lower appellate court (the learned Civil Judge). While that appeal was pending, the State Government issued a notification in the Official Gazette extending the Act to the town of Raya on 24 September 1949. On 27 September 1949 the lower appellate court held the notice valid, allowed the appeal and directed ejectment of the defendant.

The defendant obtained leave under the Letters Patent and brought a second appeal to this Court. The learned single Judge had dismissed the second appeal on the ground that section 15 of the Act did not apply because the suit was not filed before “the commencement of the Act.” The present opinion is the decision of the division bench on that appeal.

Legal Issues Presented

  1. Whether the phrase “the date of the commencement of this Act” in section 15 (and, by necessary construction, section 14) of the United Provinces Control of Rent and Eviction Act, 1947 refers to the original date fixed in the Act (1 October 1946, as per section 1(3)) or to the date on which the Act became applicable to a particular area (i.e., the date of extension by notification or the date the Act became operable in that locality).
  2. Whether, for the purposes of section 15, the word “suit” includes appeals and proceedings in appellate courts (i.e., whether suits pending includes appeals arising from them).

Arguments of the Parties

Plaintiff's Arguments

  • It was argued that section 15 must be confined to suits pending on 1 October 1946 (the date mentioned in section 1(3)) and therefore would not apply to a suit filed after 1 October 1946 with respect to an area to which the Act was extended by notification after the suit's institution.

Defendant's Arguments

  • It was urged (on behalf of the defendant) that once the Act had been made applicable to the town of Raya, the defendant could not be ejected except in accordance with the provisions of section 3 of the Act.

Table of Precedents Cited

Precedent Rule or Principle Cited For Application by the Court
Raj Narain v. Sita Ram Sri Kishen Das Held that, on a plain reading of section 15, the Act had retrospective effect to apply to suits pending on the date of commencement; and that the word "suit" includes proceedings up to the court of final appeal. Cited as primary authority for the proposition that "suit" in section 15 includes appeals and that the Act was intended to operate retrospectively to pending suits on commencement.
Niranjan Lal Bhargavrt v. Mst. Ram Kali Devi The bench held that the "suit" mentioned in section 15 includes a suit in the trial court and also while before the appellate court (an appeal is a continuation of a suit). Relied upon to support the view that appeals are covered by section 15; used to reinforce the interpretation of "suit" as including appellate proceedings.
Har Sarup v. Lokeshwar Prasad Discussed the Federal Court authorities that an appeal is a continuation of a suit and Courts of Appeal must pass decrees according to the law on the day when the case comes up for hearing. Used to corroborate the proposition that section 15 applies to suits pending in appeal as well as trial courts.
Shyamakant Lal v. Rambhajan Singh Federal Court authority referenced to show that an appeal is merely a continuation of a suit and that appellate courts rehear and apply the law as it exists when the case is heard. Cited (through Har Sarup) to support the legal principle that appeals are continuations of suits relevant to section 15's scope.
Lachmeshwar Prasad Shukul v. Keshwar Lal Chaudhari Another Federal Court decision supporting the proposition concerning appeals being continuations of suits. Referred to as part of the Federal Court authority relied upon in deciding that appeals fall within "suits" for section 15.
Quilter v. Mapleson English Court of Appeal decision showing that, even absent express retrospective words, an Act may be interpreted to give relief in proceedings pending when the Act was passed if that accords with legislative purpose (example: relief against forfeiture to a lessee). Quoted in support of the proposition that statutes intended to protect parties (here, tenants) should, where appropriate, be given an interpretation that applies to proceedings pending on the operative date.
Rup Lal v. Ram Swarup Seth Single Judge decision holding that the date of commencement of the Act was 1 October 1946 and that even in areas later extended the original date must be taken as the commencement. Reviewed by the Court as one of several authorities taking the contrary view; the division bench did not follow this view and preferred the contrary conclusion in L. Kedar Nath's case.
Shri Ram Chand v. Ram Swarup Single Judge decision expressing the same view as Rup Lal on the date of commencement being 1 October 1946. Noted among authorities taking the position rejected by the division bench in the present opinion.
Shyam Sunder Lal v. Shagun (Mushtaq Ahmad, J.) Single Judge decision consistent with the view that the date of commencement is the original date fixed by section 1(3). Referenced as one of the single Judge authorities on the contrary side of the debate; not adopted by the division bench.
L. Ganga Prasad v. Mst. Saroop Dei (P.L. Bhargava, J.) Single Judge decision holding that section 15 did not apply where the suit was instituted after 1 October 1946 but the Act was made applicable to the area during pendency of the suit. Referred to as another instance of the opposing single Judge view which the division bench declined to follow.
Abhilakh Ram v. Uma Shanker Single Judge decision mentioned but described in the opinion as not directly in point for the precise question before the Court. Not treated as decisive on the primary point; noted as not directly in point.
L. Kedar Nath v. L. Krishan Lal Division bench decision holding that, for areas to which the Act was subsequently made applicable, the date of commencement (for the purpose of section 15) is the date when the Act was extended to that area by notification. The division bench in the present opinion expressly agreed with and followed L. Kedar Nath's decision and applied its reasoning to resolve the controversy.

Court's Reasoning and Analysis

The Court began by identifying the core interpretive difficulty: the words “suits ... pending on the date of the commencement of this Act” in section 15 and whether "the date of the commencement of this Act" should be read as the single original date fixed by section 1(3) (1 October 1946) or as the date on which the Act became applicable to a particular area (for example, by a later notification).

The Court analyzed the textual scheme of the Act and the interrelation between sections 3, 14 and 15:

  • Section 3 governs suits instituted after the Act became applicable to an area.
  • Section 14 limits execution of decrees already passed before the date of commencement by requiring that ejectment occur only on grounds mentioned in section 3.
  • Section 15 expressly applies similar protection to suits pending on the date of commencement of the Act.

The Court observed that sections 14 and 15 are complementary and together were designed to cover all cases where tenants had not yet been physically ejected. To effectuate the legislative purpose — protection of tenants in areas of housing shortage and competition — the sections must be construed so as to avoid anomalous and discriminatory results.

The Court considered the mechanics of section 1(2A) (making the Act apply to municipalities, notified areas contiguous to municipal/cantonment areas, and to areas within two miles of such areas) and section 1(3) (deeming the Act to have come into force on 1 October 1946). It noted that publication in the United Provinces Gazette made the Act operative in the areas to which it applied immediately by section 1(2A), and that the Act was published on 1 March 1947.

The Court then examined the consequences of adopting the plaintiff's interpretation (i.e., confining section 15 to suits pending on 1 October 1946). It demonstrated that such an interpretation would create illogical gaps and discrimination: decrees or suits arising between 1 October 1946 and the date on which the Act became applicable in a given area (for example, 1 March 1947 in the areas where the Act applied on publication, or later dates in areas extended by notification) would fall outside the protective scope of sections 3, 14 and 15. That would leave certain tenants with no protection even though the legislature's object was to protect tenants generally where housing pressure justified it.

The Court relied on earlier division bench rulings (notably L. Kedar Nath) and on authorities establishing that the word "suit" in section 15 includes appeals (citing Raj Narain, Niranjan Lal Bhargavrt and related authorities) to show that the Act should operate to protect tenants in pending proceedings up to final appellate determination. Having considered prior conflicting single-judge authorities (Rup Lal, Shri Ram Chand, etc.) the Court concluded there was no reason to depart from L. Kedar Nath's approach.

On balance, the Court held that the phrase “the date of the commencement of the Act” in sections 14 and 15 must be understood, with reference to a particular area, as the date on which the Act became applicable to that area (e.g., by publication or by notification), because this interpretation effectuates the legislative purpose and avoids anomalous results.

Holding and Implications

Core Ruling:

The words “the date of the commencement of the Act” in section 15 (and, by necessary construction, section 14) mean the date on which the Act was made applicable to the particular area in question.

Direct consequences in this case:

  • The division bench allowed the appeal and set aside the decrees passed by the lower courts.
  • The matter is remitted to the trial court through the lower appellate court with directions to readmit the case to its original number.
  • The parties are to be given an opportunity to amend their pleadings in the light of the provisions of section 3 of the Act, and the parties have the right to tender fresh evidence.

Broader implications explained by the Court:

  • Sections 3, 14 and 15 are complementary: section 3 governs suits instituted after the Act becomes applicable to an area; section 14 governs execution of decrees passed prior to the date on which the Act became applicable; section 15 governs suits pending on that date (including appeals). Interpreting "commencement" as the date the Act becomes applicable to each area ensures consistent protection for tenants and avoids anomalous gaps.
  • The Court expressly followed the division bench decision in L. Kedar Nath v. L. Krishan Lal and declined to follow single-judge decisions holding to the contrary.
Appeal allowed.

Note: This summary is confined strictly to material contained in the provided opinion. No information has been added beyond what appears in the opinion itself.

    Hazari Lal v. Kanhaiya Lal

    B. Malik, C.J:— This is an appeal against the judgment of a learned single Judge of this Court and the point raised relates to the interpretation of the provisions of the United Provinces Control of Rent and Eviction Act, 1947. This; Act received the assent of the Governor General on the 28th of February, 1947, under section 76 of the Government of India Act, 1935, and was published in the United Provinces Government Gazette Extraordinary, on the 1st of March, 1947. section 1(3) of this Act provides that the Act shall be deemed to have came into force on the 1st day of October, 1946.

    On the 10th of May, 1947, a suit was filed for ejectment of the defendant from a shop situate in the town of Raya. It is the common case of the parties that at the time when the suit was filed the United Provinces Control of Rent and Eviction Act had not been extended, by notification of the State Government, to apply to the town of Raya. In view of that admission it is not necessary to deal with the various amendments made to the original sub-section (2) of section 1 of the Act at length but we might quote the sub-section as it originally stood and indicate how it was later amended. The original sub-section (2) of section 1 of the Act was as follows:—

    “1.(2) It extends to the whole of the United Provinces and applies to the municipal areas, cantonment areas and to every notified area contiguous to such municipal area situated in these provinces and to accommodation situated within one mile of the boundaries of any such municipal area, cantonment area, and notified area, and to such other areas as the Provincial Government may, from time to time, notify in the official Gazette in this behalf…”

    This sub-section was amended by the Amending Act XLIV of 1948 and it was divided into two sub-sections, sub-section (2) and sub-section (2-A). This was later again amended by a number of ordinances and notifications and the latest amendment is by Act No. XVII of 1951. The two sub-sections now read as follows:—

    “(2) It shall extend to the whole of the United Provinces.

    (2-A) It shall apply to every municipality, notified area contiguous to a Municipal or Cantonment Area and to areas situate within two miles of such municipality or notified area:

    Provided that the State Government may, by notification in the official Gazette, declare that it shall cease to apply to any area or shall apply in whole or in part to any other area, as may be specified.”

    The suit was contested on various grounds and one of the grounds, we are informed by learned counsel, was that the notice for ejectment was defective.

    On the 21st of July, 1948, the suit was dismissed as the notice for ejectment served on the defendant was found to be not in accordance with law.

    An appeal was filed before the learned Civil Judge and, while that appeal was still pending, the Stater Government by a notification in the official Gazette extended the operation of the Act to the town of Raya on 24th September, 1949. On the 27th of September, 1949, the lower appellate court held that the notice was valid, allowed the appeal and directed ejectment of the defendant.

    The defendant came up in second appeal before this Court and it was urged before the learned single Judge that, after the Act had been made applicable to the town of Raya, the defendant could not be ejected, except in accordance with the provisions of section 3 of the Act. This argument did not find favour with the learned jingle Judge and he dismissed the appeal but allowed leave to file an appeal under the Letters Patent. The learned single Judge was of opinion that section 15 of the United Provinces Control of Rent and Eviction Act did not apply to this case as the suit was not filed before “the commencement, of the Act.”

    On the question as to the applicability of section 15 of the United Provinces Control of Rent and Eviction Act there has been considerable difference of opinion in this Court. Section 15 is as follows:—

    “In all suits for eviction of a tenant from any accommodation pending on the date of the commencement of this Act, no decree for eviction shall be passed except on one or more of the ground mentioned in section 3.”

    The argument for the plaintiff is that section 15 must be confined to suits pending on the 1st of October, 1946, and, it will not apply to a suit which may have been filed after the 1st of October, 1946, with respect to an area to which the Act was extended by a notification of the State Government after the institution of the suit.

    The scheme of the Act had been carefully considered in several division bench rulings of this Court and it is not necessary for us to cover the same ground. It was pointed out in those cases that sections 14 and 15 of the Act should be read together and between the two sections it was intended that all cases of ejectment of tenants should be covered. Section 14 deals with cases where a decree was passed before the date of commencement of the Act but the decree was being executed after the date of commencement. In such cases even though the decree had become final, section 14 directs that the decree shall not be executed and a tenant shall not be ejected except on any of the grounds mentioned in section 3 of the Act. For suits instituted after the Act came into force no express provision was necessary as the Act would apply to such suits and the cases will have to be decided in accordance with the provisions of the Act, and, as regards Hits pending on the date when the Act came into force, section 15 expressly provided that to them the Act will apply and they will have to be decided in accordance with provisions of section 3. So far, therefore, as areas to which the Act applied when it was passed, there is no difficulty and this Court has held in at least 3 division bench rulings that the word ‘suit’ in section 15 of the United Provinces Control of Rent and Eviction Act includes not only the suit but also appeals arising therefrom. The first case on the point decided by a bench of this Court is Raj Narain v. Sita Ram Sri Kishen Das. This case was decided on the 3rd of November, 1949. It was observed in that case that—

    “Confining ourselves to the language of section 15 alone it would appear that the Act was intended to have a retrospective effect and to apply to all suits for eviction of a tenant pending on that date of the commencement of the Act. It further appears to make it clear that no decree for eviction shall be passed against a tenant except on one or more of the grounds mentioned in section 3.”

    It was then held that the word ‘suit’ in section 15 was intended to apply not only to suits pending in the trial court but also to a suit in its later stages right, up to the court of final appeal. It is not necessary to repeat the reasons given for these findings as they are already mentioned in the decision which has now been reported. Independently of this decision, as the case had not been till then reported, another bench of this Court took the same view in Niranjan Lal Bhargavrt v. Mst. Ram Kali Devi(2). After having carefully examined the provisions of the Act, the Bench held that—

    “the Act does not anywhere provide specifically for appeals and we consider that the ‘suit’ mentioned in section 15 includes a suit while it is before the court of first instance and also while it is before the appellate court. An appeal is but a continuation of a suit. The learned counsel for the appellant is, therefore, right in his contention, that the decree for the eviction of the appellant should not be passed unless it is shown that the case is covered by any one or more of the grounds mentioned in section 3 of the Act.”

    The same point arose before another bench in Har Sarup v. Lokeshwar Prasad. The arguments were again considered in this case and it was observed that the Federal Court in Shyamakant Lal v. Rambhajan Singh and Lachmeshwar Prasad Shukul v. Keshwar Lal Chaudhari(3), had held that—

    “an appeal was merely a continuation of a suit and Courts of Appeal in India were not merely courts of error and the hearing of an appeal was in the nature of a re-hearing of the suit so that the Courts of Appeal must pass decrees in accordance with law that exists on the day when the case comes up for hearing.”

    It was, therefore, held that section 15 not only applied to a case where a suit was pending in the first court but also to a case where a suit was pending in an appeal. So far, therefore, as this point is concerned, the decisions of this Court appear to be all one way and even in cases where learned Judges have taken the view that the Act does not apply to a case which had been instituted after the 1st of October, 1946, relating to an area to which the notification was made after the institution of the suit, the proposition of law that the word ‘suit’ in section 15 includes an appeal, has not been doubted.

    The whole difficulty has arisen by reason of the words “suits…. pending on the date of the commencement of this Act” in section 15 of the Act. It is urged that the date of the commencement of the Act must be deemed to be the date fixed in accordance with the provisions of section 1(3) of the Act and even to areas to which the Act was later made applicable, the date of commencement of the Act is the date fixed in the Act itself, i.e the 1st of October, 1946. Reliance is placed on the United Provinces General Clauses Act, 1904, where the word “commencement” has been defined in section 4(10) as follows:

    “Commencement', used with reference to an Act, shall mean the day on which the Act comes into force.”

    This definition, however, must be read subject to the opening words of the section that “In all United Provinces Acts, unless there is anything repugnant in the subject or context” the definition in the General Class Act were to apply. Reliance is also placed on section 5(2) of this Act which is as following.”

    “Unless the contrary is expressed, a United Provinces Act shall be construed as coming into operation immediately on the expiration of the day preceding its commencement.”

    Sub-section (2) or section 5 is not helpful as in the case before us a contrary intention was expressed in the Act itself. The Act was passed by the Legislature in 1947 it received the assent of the Governor General on the 28th February, 1947, and was published in the official Gazette on the 1st of March, 1947, but it was made retrospective and was to operate from the 1st of October 1946, at any rate with respect to the area to which the Act was applicable without any notification of the United Provinces Government. The whole point for decision, therefore, is whether the words “the date of the commencement of this Act” in section 15 mean the original date when the Act came into force or the date when the Act was made applicable to a particular area. The learned Judges, as we have already said, are divided in opinion. In Rup Lal v. Ram Swarup Seth, J. held that the date of the commencement of the Act was the 1st of October, 1946, and even to areas to which it might have been extended by a later notification the original date fixed in section 1(3) must be deemed to be the date of the commencement of the Act. The same view was expressed by him in another case in Shri Ram Chand v. Ram Swarup. The same view was also taken by Mr. Justice Mushtaq Ahmad in Shyam Sunder Lal v. Shagun. Mr. Justice P.L Bhargava also took the same view in L. Ganga Prasad…Defendant; v. Mst. Saroop Dei…Plaintiff.(4), and held that section 15 did not apply to a case where a suit was instituted ofter the 1st of October, 1946, but the Act was made applicable to that, area during the pendency of the suit the only other single Judge decision to which reference has been made is not directly in point and that is the case of Abhilakh Ram v. Uma Shanker(5). The point was, however, carefully considered by a division bench of this Court in L. Kedar Nath v. L. Krishan Lal(6). Mr. Justice Bind Basni Prasad after having Carefully considered the previous authorities on the point, came to the conclusion that to areas to which the Act was subsequently made applicable the date of commencement of the Act within the meaning of section 15 must be the date when the Act was so extended by notification. Learned counsel has urged that the decision of the bench in L. Kedar Nath's case should be reconsidered by a larger bench. We have, therefore, heard him at some length and we are not satisfied that there is any reason to differ from the conclusion arrived at an Kedar Nath's case.

    As we have already said, the Act was intended for the benefit of tenants in view of the shortage of housing accommodation in the State. The Act was made applicable to municipal and other areas where there was the greatest pressure and it was later extended to every area where the State Government thought it necessary to give protection to the tenants by reason of lack of accommodation and competition for housing accommodation. The Act must be interpreted so as to carry out the intention of the legislature and to give protection to tenants for whose ejectment decrees had either already been passed or proceedings for whose ejectment were pending either in the trial court or a court of appeal. It was pointed out in Raj Naram v. Sita Ram Sri Kishen Das, that in Quilter v. Mapleson, though there was nothing in the Act to show that it was retrospective, the Court of Appeal held that the Act was passed with the intention of giving relief against forfeiture to a lessee and the Act must be so interpreted as to give that relief even in proceedings which were pending before the court on the day when the Act was passed.

    In order to achieve the object of protecting tenants from ejectments by landlords, except under special circumstances mentioned in section 3 of the Act, provision was made for different contingencies that could arise. Section 3 obviously governs all suits which were or may be instituted after the Act became applicable. Where decrees had already been passed the fight of execution and claim ejectment of the tenant was limited by section 14. Section 15 was enacted in order to apply the same principles to suits which were pending. Obviously the three sections are complementary to one another and are designed to cover all cases of tenants who had not yet been physically ejected from the accommodation which they were occupying as tenants. This object of granting protection to all the tenants would only be achieved if it be held that sections 14 and 15 would govern all decrees already passed and all suits already instituted up to the date on which section 3 came into effect so as to govern all suits instituted thereafter. Obviously, therefore, the date of commencement of the Act mentioned in sections 14 and 15 must be the date on which section 3 of the Act came into operation so as to govern suits instituted thereafter. The date of the commencement of the Act for purposes of sections 14 and 15 must, therefore, be the date on which the Act became applicable. In the case of every municipality, cantonment areas, every notified area contiguous to a municipal or cantonment area, and every area situate within two miles of such municipal or notified areas, the Act became applicable as soon as the Act was published by virtue of section 1(2A) of the Act. Under sub-section (3) of section I the Act was deemed to have come into force on the 1st day of October, 1946, but even in those arrears the Act became applicable only on the 1st day of March, 1947 when the Act was published in the Uttar Pradesh Gazette Extraordinary of that date. Suits instituted on or after the 1st day of March, 1947 would, in such areas, be governed by section 3 of the Act and the purpose of the Act can only be served if sections 14 and 15 are so interpreted that all decrees passed before the 1st day of March, 1947, are governed by sections 14 and 15. In respect of the other areas to which the Act was made applicable by a notification issued by the State Government subsequently the same purpose would be achieved if a similar interpretation is put, so that suits instituted after the date on which the Act was applied to those areas would come within the purview of section 3 of the Act, whereas all decrees passed up to that date and all suits pending on that date within, the purview of sections 14 and 15.

    On the interpretation sought to be put on the words “Commencement of the Act” in sections 14 and 15 by learned counsel for the plaintiff, section 3 would only govern suits instituted on or after the date on which the Act became-applicable, whereas sections 14 and 15 would govern decrees passed before the 1st day of October, 1946 or suits pending on that day. The result would be that decrees passed between the 1st day of October, 1946, and the 1st day of March 1947, in the case of areas to which the Act was made applicable as soon as published under sub-section (2A) of section 1, and suits instituted after the 1st day of October, 1946, and before the 1st of March, 1947, arising out of the said areas would not be governed by the provisions, of sections of 14 and 15. Similarly, in other areas to which the Act might be applied later by a subsequent, notification, decrees passed between the 1st day of October, 1946, and the date on which the Act was applied as well as suits instituted between these two dates, would not be governed by these sections of course, section 3 can, in no case, govern these decrees and suits. There might be cases where a suit might have been instituted after the 1st of October, 1946, and decided on some day prior to the date on which the Act became applicable to the area from which that suit arose and such decrees would also not be governed by the provisions of the Act at all. It is clear that the legislature could never have intended to create discrimination between various tenants and to grant no protection a all to those tenants against whom suits were instituted after the 1st of October, 1946, and which were either decreed before or were still pending on the date on which the Act was applied to the area from which the suit arose. The interpretation that would create such an anomalous position must, therefore, clearly be ruled out.

    The words “commencement of the Act” in sections 14 and 15 with reference to a particular area, must be interpreted to mean the date on which the Act became applicable to that area. This is the only interpretation that would effectively serve the purpose of the Act. We, therefore, agree with the decision in Lala Kedar Nath's case and hold that the words “the date of the commencement of the Act” in section 15 of the Act must mean the date when the Act was made applicable to an area.

    We, therefore, allow the appeal, set aside the decrees passed by the lower courts and send/the case back to the trial court through the lower appellate court to readmit it to its original number and to give the parties an opportunity to amend their pleadings in the light of the provisions of section 3 of the Act. The parties, will have the right to give fresh evidence.

    Appeal allowed.

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    Comments

    Hazari Lal v. Kanhaiya Lal
    (Mar 13, 1953)