The research undertaken would analyse the importance of lien and its kinds by understanding the various provisions and judgments decided by several Acts and legislation. The paper would firstly define what lien is and how it is defined under the Special Contract Act. Further the paper would understand the various types of liens and how they have evolved with the help of decided cases in India and thereby the paper would further dwell into understanding and interpreting the scope of lien and how its applicability can be understood. The researcher would then elucidate how various key legislation have explained and interpreted lien and suggestions can be incorporated to improve the various distinctions of lien. Lastly, the researcher would statistically analyse the data collected to get a brief overview about lien and its kinds and this indeed would help us describe the various facts and questions that come to our mind when we think of lien and its kinds.
So a lien is basically a legal right granted by the owner of the property, by the creditor or by law. It also serves as a guarantee to an underlying obligation, like the repayment of a loan. If that underlying object is not satisfied, then the creditor may also be liable to seize that asset on subject of the lien. It becomes the legal right of a creditor to sell the collateral property of a debtor once a lien is executed when failed to meet the obligations of a loan or other contract.
Various illustrations of a lien are:
- When a person takes a loan from a bank for automobiles.
- Another is when a property is at risk, this is known as the mechanic’s lien.
There are often times that several statutory liens are created by laws which oppose those created by contract. These type of liens are common in terms of field of taxation, where such tax authorities allow to put liens on the property of delinquent taxpayers.
In layman’s language a lien is often a claim that someone has on property that oneself possesses or uses. Example of a lien is a payment agreement for a car loan. The loan granted will include documents having provisions to allow the lender to keep the person from selling the car until the money owed is paid.
The word lien is derived from a Latin word meaning “to bind”. It means that a lien binds a debtor to the owner of a property until the debt is paid off. There are two main types of liens particular and general.
The scope of the following research paper is very wide and also that the following topic a detail study of Importance of Lien and its kinds is very constructive in nature and a lot of research can be laid upon. Lien is a form of a contractual agreement and it is the right of a contracting party to take possession of a specific asset of other contracting party, in case the contract isn’t performed in keeping with its terms.
A lien is a legal document signed by a general contractor, subcontractor, supplier or material prior to or in exchange of payment. Lien is applicable on mostly each and every topic of common interest from repayment of loans, to property to medical injury cases to paying off a tailor or a diamond merchant etc.
In discussion of a medical lien it is to be noted that a hospital is entitled to file for repayment of any money spent on treating or taking reasonable care of someone injured in an accident. Some medical providers even ask the patients attendant to sign a lien letter, stating that the patients submits a lien against the settlement to pay for the services rendered as applicable.
Also a lien can be issued in a work-related accident, where a workers compensation lien may be issues if the medical bills or lost wages have been paid through the state worker’s comp fund.
The scope of lien can be explained in the case of Transport & General Credit Corp. vs. Morgan where it was stated that the right of lien wholly depends upon the statutory provisions and not upon any equitable considerations. Therefore it is clear that the seller is not entitled to lien for any other charges like charges for storage or refrigeration etc. Also in the case of Somes vs. British Empire Shipping Co. It was contended that where the price has been rendered the seller cannot claim to return the goods further for the expenses incurred by him on storage during that period of time where he was holding the goods in the exercise of his lien.
Review of Literature
This research paper is primarily based on secondary data, i.e., books, articles and magazines and both first hand and second hand data. To further elucidate on the literature adopted from various renowned and learned individuals in the field we would like to throw some light on the various messages these individuals have to say about lien and its importance stating the various types associated to it as well.
Academia states about bankers right to lien customers deposits, its legal implication, challenges and applicability.
“The genesis of lien can be traced back to common law, it is the right given to a person to retain that which is right full and continuously in his possession belonging to another until the present and accrued claims of the person in possession is satisfied.”
“In common law the word ‘lien’ is used in a legal sense to mean having a charge or claim on property either real or person as security for the payment of some debt or obligation. Initially when banking was expanded, it was noticed that many of them were unwilling to loan amounts for a longer duration of period or to certain class of people who are unable to provide securities. However, the bank has transformed itself into a new lending form, where the banks required very strong and safe securities which the banker would retain till the loan was paid off by the customer”
This paper has also made use of a close-knit survey adopting the method of questionnaire sampling that had been carried out within a very small respondent size, so as to get an all-over idea about the opinion of the students and practitioners in this field about how much they are aware and well versed with lien as a an important right.
Brief Characteristics of Lien
The Bailee may retain the good if his lawful charges are not paid. This right of to retain any property until the charges for the same are paid is called the Right of Lien. The Halsbury’s Laws of England were helpful for the Supreme Court to hold that:
“Lien is in its primary sense a right in one man to retain that which is in his possession belonging to another until certain demands of the person in possession are satisfied. In this primary sense it’s given by law and not by contract.”
In the case of Syndicate Bank vs. Vijay Kumar and in the case of V.S. Prabhu vs. R.D. Mujumdar it was contended by the SC that the Bailee cannot be deprived of his possession for any superior claim. He has to be paid first. Where goods were taken away from bailee under court order, his lien survived and applied to the sale proceeds of the goods for his payment.
Therefore, we can say that till the other person meets the demands of the person in possession, Lien is a right to retain the possession of a property of another. The demand for the same could constitute of either pay a due sum of money or of performing a duty. Holding on to a thing of another thanto let it go and spend time and resources in seeking a remedy was a common sense of practice during the early stages of the development of trade and commerce. This practice was recognized by the Common law courts as a ‘self-help’ remedy. There was no intervention from the courts, therefore it was termed as a ‘self-help’ remedy. It was starting to feel that if such ‘primitive’ remedy was allowed freely, with the development of trade and commerce, it would lead to every other person recklessly holding on to whatever he/she had. This could cause serious repercussions on the impeded trade and commerce. Therefore we can say that Common law courts did both things essentially i.e. one recognize it and secondly limit its application.
A lien was recognized as a right since it was in the nature of a remedy. This elucidates that its genesis was not in a contract between the parties. Also it is generally seen that parties do not provide in their contract that they would have a lien over the property of another. This right was exercised by the party since the Common law courts recognized them. Therefore the basis of a lien was established by common law courts. These are some instances where the right of lien was recognized. Firstly, when an unpaid seller had a lien over the goods in his possession. Secondly, where an agent had a lien on the property of the principal, for unpaid remuneration. Thirdly, when the bailee had a lien on the property in his possession. The only notable difference between a lien and a pledge is that, the person in possession has only the right to retain the possession of the goods. Whereas, he is not entitled and has no rights to sell the property. A lien is a right whereas, a pledge is created by a contract between the parties. Like in a generic example a lien could be a performance of a duty, which invariably can be exercised for the payment of a due sum. But on the other stance in a pledge the crucial factor of the exercise of a lien is that the other person must have been voluntarily given the possession of the goods. Therefore, based on the above reasons we can say that a lien is a security for a person who has come to become a creditor.
Like in the case of Diplock in Tappenden vs. Artus which describes the nature of a lien it is said that:
“It is said that since the early and imperfect stage of development, the common law of lien is from a very ancient origin, dating from a time when remedies by action upon contracts was still not exercised. Also it was laid out that if pursuant to the contract, the artificer does his work, he is entitled to retain possession of the goods so long as his charges, whether agreed in advance or payable upon a quantum meruit, so satisfied.”
Like other primitive remedies, the common law remedy of a possessory lien is a self-help remedy and does not need to exercise any intervention from the courts, for it can only be exercised by an artificer who contains actual possession of the goods subject to obtaining the lien. In a lien in order to obtain the right of possession takes places immediately.
Lien described by common law courts can be divided into two types:
- Particular Lien
- General Lien
A particular lien is where a right to retain possession of the goods takes place until the charges in due respect of that property were paid. On the other hand a general lien is where a right to retain possession for the moment of any sum owed, even if the payment was not connected with the property in the session. The basis and analysis of a Particular lien is done in Section 170 of the Act and about a General lien is done within the Section 171 of the said Act.
Section 170 of the ICA, 1972 defines a Particular lien as:
“Where the bailee has, in accordance with the purpose of the bailment, rendered any respect of the goods bailed, he has, in the absence of a contract to the contrary, a right to retain such goods until he receives due remuneration for the services he has rendered in respect of them.”
This Section can be explained by the following illustrations:
- X gives cloth to Y, a tailor, to make into a suit piece. Y promises X to deliver the suit piece as soon as it is finished, and to give X five months credit for the price. Y is not entitled to retain the suit piece until he is paid.
- P delivers a rough gemstone to Q, a merchant, to be cut and polished, which is accordingly done. Q is entitled to retain the stone till he is paid for the services he has rendered.
Principle of Bailee’s Lien
This elucidates the common law principle that:
“If a man has a good delivered to him, on the improvement of which he has to bestow trouble and expense, he has a right to detain it until his demand is paid.”
“Where a bailee has expended his labour and skill in the improvement of a chattel delivered to him, he has a lien for his charge in that respect. Thus the artificer to whom the goods are delivered for the purpose of being worked up into form, or the farrier by whose skill the animal is cured of a disease, or the horsebreaker by whose skill he is rendered manageable, have liens on the chattels in respect of their charges.”
It deals with a lien of a bailee in respect of the goods bailed only. Only if the service regarding labour and skills has been rendered this lien can be exercised, also provided it is in accordance with the purpose of the bailment. The bailee won’t be allowed to exercise the right of particular lien if the service is not rendered in accordance with the terms of the contract. The same principle was emphasized in the case of Skinner vs. Jager. If the bailee has parted with the possession of the goods bailed, then he loses the right of lien. If a person working for deliveries under a full contract then it does not matter if the deliveries are at different times. This does not affect the right to a lien on all goods dealt with under the contract. This was emphasized in the case of Chase vs. Westmore.
Also in the case of Miller vs. Nasmyth’s Patent Press Co. Ltd where jute was delivered to a pressing company from time to time to be bailed, but all under one contract, the lien was held to attach to all such goods.
Similarly in the cases of British Empire Shipping Co vs. Somes and Hartley vs. Hitchcock it was held that generally a bailee exercising a lien is not entitled to charge for storage of goods. Also in the landmark judgment of Om Shankar Biyani vs. Board of Trustees, Port of Calcutta it was contended that cost of storage may be charged where the lien is exercised under a particular statute and in the case of Shipping Corporation of India Ltd. vs. CL Jain Woolen Mills the court held that where there is a lien it is itself exercised for non-payment of such charges.
No transfer of Lien
Under this it is clearly specified that a bailee for reward cannot transfer his lien to a sub-contractor without the Bailor’s authority. This principle was contended in the case of Penniagton vs. Reliance Motor Works.
Contract to the Contrary
It is often noticed that there is no room for a quantum meruit when there is an express contract to do certain work for a specified sum of money.
Exercise of Labour or Skill
The above right can be implemented based on certain conditions. The main motive and force of the above condition is that the bailee must have rendered some service involving the exercise of Labour or skill in respect of goods bailed. If the Labour or skill of the bailee does not improve the goods then right to lien won’t be allowed.
In the case of Hutton vs. Car Maintenance co it was held that
“There is no authority for the proposition that what the contractor does is not to improve the article, but merely to maintain it in its former condition, he gets a lien for the amount spent upon it for that maintenance. A job master has no lien at all for the moment of his bill in respect of feeding and keeping a horse at his stable, whereas a trainer does get a lien upon a horse for the improvements which he effects to the horse.”
Also in another case of Vithoba Laxman Kalar vs. Maroti Ukandsa Kalar, it was held that a person to whom cattle are given for grazing does not have the right of lien on them for his charges.
Also there are exceptions when the bailee has not rendered services involving the exercise of labour and skills within the meaning of Section 170, the bailee was not entitled to lien. This principle was laid down in the cases of Chand Mal vs. Ganda Singh and Kalloomal Tapeshwari Prasad & Co vs. RC&F Ltd.
The right of lien solely depends on the possession of the goods, if the possession is lost then the right to lien is also lost. In the case of Eduljee vs. Café John Bros it was held by the court that delivery of possession after repairs are affected puts an end to the lien which the repairer has for the charges of repairs and cannot be revived because the repairer undertakes further repairs merely out of grace and not as a matter of fresh contract.
This principle was also contended in the case of Surya Investment Co. vs. State Trading Corpn of India (P) Ltd where the bailee lost his lien because of the goods in his cold store claimed by a special officer, the bailee was allowed by personal action to recover under S. 158 his expenses of storage.
Various Indian Statutes for Particular Lien are:
- Lien of a finder of goods – Section 168
- Bailee’s lien – Section 170
- Pledge’s or Pawnees lien – Section 173
- Agent’s lien – Section 221
- Unpaid vendors lien – Section 47 of the Sale of Goods Act
- A partner’s lien on surplus or assets of a firm in partnership is rescinded on the ground of fraud – Section 52 of the Indian Partnerships Act
This is the right to hold goods bailed as security for a general balance of account. This right of particular lien entitles a bailee to detain only that particular property in respect of which charges are due. However, a general lien entitles the bailee to detain any goods bailed to him for any amount due to him whether in respect of those goods or any other goods. We can explain the following topic with these illustrations:
- Two securities are given to a banker but a loan has been taken only against one of them, the banker may detain both securities until his dues are paid.
- Also where a quantity of imported pork was stored with the housekeeper who by a general term of the trade had a general lien, it was held that he could retain the pork for his charges due in respect of other goods.
This was however further explained in the case of Jowitt & Sons vs. Union Cold Storage Co.
Section 171 of the Indian Contract Act, 1872 defines a General Lien as:
“Bankers, factors, wharfingers, attorneys of a High Court, and policy-brokers may, in the absence of a contract to the contrary, retain, as a security for a general balance of account, any goods bailed to them; but no other persons have a right to retain, as a security for such balance, goods bailed to them, unless there is an express contract to that effect.”
General as Different from Particular Lien
As we know that a general lien is a right to retain any property of another for a general balance of accounts due to the persons specified, on the other hand a particular lien is a right to retain it only for a charge on account of labour or skill employed or expenses bestowed upon the identical property detained.
Also another plausible difference is that a general lien can be exercised only in respect of property of another and not in respect of one’s own property. This principle was determined and analytically explained in the case of Brahmaya vs. Thangavelu.
The general lien was originally established in England and it became a part of the law merchant as to be judicially noticed as any other part of law. This was contended in the case of Brandao vs. Barnett.
Effect on Right of Lien under Special Statute
Unless the statute specifically excludes application of this Section, the right given is not lost due to any special statute governing the particular bailee and providing for lien. In the case of Board of Trustees of the Port of Bombay vs. Sriyanesh Knitters it was held that giving right of particular lien and sale to a port trust do not exclude the general lien available to the port trust as a wharfinger.
Lien of Bankers
The right deposited with a banker does not extend to securities or other valuable property for safe custody of for a special purpose and also on the ground that limited ground and special purpose must be deemed to imply a contract to the contrary. This principle was showcased in the case of Cuthbert vs. Robarts, Lubbock & Co. also this right does not extend to a trust account nor the property of the consume as laid down in the case of Lloyds Bank Ltd. vs. Administrator General of Burma.
In the case of Wolstenholm vs. Sheffield Bank it was held that the banker had no lien for the general balance due from the firm since a member of a firm deposited a lease to secure a particular advance to the firm. If the title deed is left casually at the bank after a refusal by him to advance money on them the lien of a banker does not extend. The same was held in Lucas vs. Dorrein.
Also in the case of Agra Banks Claim it was held that a general lien may be excluded by a special agreement, whether express or implied from the circumstances, the agreement must be clearly inconsistent with the existence of such a lien. Similarly a banker’s lien extends to all bills, cheques, and money entrusted or paid to him, and all securities deposited with him, in his character as a banker if it is not excluded by a special contract, express or implied. This was held in the case of Misa vs. Currie.
Lien of Factor
The definition of a factor was held in the case of Stevens vs. Biller in which it said that “A factor is an agent entrusted with the possession of goods for the purpose of sale.” It was also held that the agent known as a factor may buy and sell either in his own name or in that of the principal, though “he usually sells in his own name, without disclosing that of his principal.” The goods consigned to him have a “special property” known as the factor. This special property was discussed and elucidated in the case of Baring vs. Cowie.
Also if private instructions to sell any principal’s claim or within fixed price will not make the factor of less importance or deprive him from his claim of a lien. This was elaborated in the case of Stevesn vs. Biller. In the case of Peacock vs. Bajinath it was held that a banian in Calcutta is not a factor and has no lien for general balance of accounts since there was absence of a contract to the contrary. A factors lien, only applies to debts due to the factor in that character and does not extend itself to debts which arise prior to the time at which his character of factor commences, conformably to the principle governing it. This principle was emphasized in the case of Houghton vs. Mathews.
A person in charge of handling of freight, loading, unloading, storage, removal of goods at the port or wharf on behalf of importers and exporters of goods is called a wharfinger. This definition was laid down in the case of Board of Trustees of the Port of Bombay vs. Sriyanesh Knitters. The lien of wharfingers is only effective as regards claims against the owner of the goods. After the notice of the sale the wharfinger has no lien against a buyer for charges becoming due from the seller before the goods are sold. This principle was held in the case of Barry vs. Longmore. Also before it comes under the hands of the wharfinger the contract of sale should be rescinded and also that that lien would be available for a general balance from the buyer. This was contended in the case of Richardson vs. Goss.
Attorney of the High Court
A solicitor has a lien on his client’s documents entrusted to him as solicitor in England for all taxable costs, charges and expenses incurred by him as solicitor for client; but he has no lien for ordinary advances or loans. This was contended in the case of Sheffield vs. Eden. Also it was contended that documents entrusted should not be only deed and law papers and this was laid down in the case of General Share Trust Co. vs. Chapman.
Also in the case of Re Taylor Stileman and Underwood it was held that those taxable costs, charges and expenses would include money payments which the party makes for his client in the course of their business such as counsel’s fee. Similarly a solicitor also has a lien for his costs on any fund or sum of money recovered for his client. This above principle is also applicable for solicitors in India as laid down in the cases of Devkabai vs. Jefferson and Mangal Chand vs. Purna Chandra.
Subject to his lien for costs a solicitor who is discharged by his clients holds the papers entrusted to him. But on the other hand if the solicitor discharges himself he is not entitled to lien according to English law and the same has been applied to Indian law in the case of Atool Chandra Mukerjee vs. Shashee Bhusan.
In the case of RD Saxena vs. Balram Prasad Sharmathe right of lien of advocates was considered by the SC and it was held that the word ‘good’ refers to ‘saleable goods’ and a client’s litigation files not being marketable commodities, no lien over these was possible.
A policy broker is an insurance agent who is employed to effect a policy of marine insurance. The lien of such a policy maker is extended to any balance on any insurance account due to him from the person who employed him to effect the policy.
Lien Against Time-Barred Debt
The great advantageous fact about the right of lien is that is can be put to practice for the realization of a debt even when an action for recovery of the debt would be time barred. In the case of Bombay Dyeing & Mfg Co Ltd vs. State of Bombay and S. Vasupalaiah vs. Vysya Bank it was held that even if the remedy of recovering debt from the principal debtor was barred by limitation, the liability subsisted and the bank was entitled to appropriate the debt due from the amounts which were in its possession either belonging to the principal debtor or the surety. In the absence of special contract, there is general lien in favour of the bank over the securities and amounts in its possession.
In the case of M.V. Al Quamar vs. Tsavliris Salvage (International) Ltd it was held by the SC that there are 2 attributes to maritime lien:
- A right to a part of the property in the res;
- A privileged claim upon a ship, aircraft or other maritime property in respect of services rendered to or inquiry caused by that property.
The property in the event of the cause of action arising and remains attached in the case of maritime lien. If this is not enforced by an action then it is inchoate and very little positive in value.
Until the dues are paid, a carrier has the right to retain the goods. Without the payment of demurrage even if the detention was issues by the Customs Authorities a carrier cannot be forced to deliver the goods.
Lien of Port Trust
The provisions of Chapter VI of the MTP Act does not cover the General lien contained in Section 171 of the ICA, 1872. This Act however does not deal with the general lien in respect of amount due on earlier consignments for which payment has not been made. Also this Act would not be applicable to wharfingers as laid under the case of American President Lines Ltd vs. Port of Bombay.
General Balance of Account
Under the Section 42 of the MTP services undertaken have to be paid for and any amount so due would be regarded as a part of the GBA. This Act provides for the right for lien, while Section 61 grants the power to sell the goods and realise the dues.
Lien of Chit Fund Company
In a chit it has been held not to be that of a creditor and debtor, but contractual. The chit amounts are liable for lien and the same can be experienced by the chit fund company. In the case of Margadarsi Chit Fund Co Ltd vs. Sd Fayazuddin it was held that the company was entitled to seek the relief of attachment before judgment against the prize money of the surety in another chit.
A set off can be carried out even without any bailment and therefore it is different from lien. In another case of Central Bank of India vs. Kesharao Narayanrao Patil that adjustment of the rent amount against the loan amount was held to be quite alright.
- There should be wider scope catering towards the rights of liens.
- More provisions should be enforced under Section 170 and 171 of the Indian Contract Act of 1872.
- The lien on bankers should be more secure and transparent and should target the right people for loans who can guarantee financial stabilities.
- The types of lien should be divided more categorically.
- The importance of lien as a right should be established from its genesis.
- An Agents lien should be entitled for a better prospective from law.
- More Literature from varied and learned professionals in the field should be encouraged and elucidated in the texts.
- A more advanced and detailed law should be enacted and major specifications should be given to particular and general lien.
- The scope of advancement in maritime lien should be incorporated.
- The lien on general basis should focus more on rigid implementations and strict adherence hence from.
“It’s a very serious negative item on your report, on par with a tax lien or bankruptcy. You will definitely pay more for your credit, in higher interest rates and higher down payments.”
In the end I would like to conclude by saying that it is very essential to understand what a lien is and to know what importance it holds and also the multitude of types of liens present. This study helps to understand various other concepts under the Law of Special Contracts like pledge, concept of bailee, Sale of Goods, Finder of Goods, concept of Agent and sub-agent, rights of lien related to property, tax, and loan and maritime. We can therefore say that a lien is a lender’s claim against a collateral asset that may be legally sold should the borrower fail to repay the loan. It is important because it protects the lenders in events of non-payments and also since loans come with collateral which have become less riskier for the buyers nowadays as they can borrow at lower rates of interests. We can state an example like when we purchase a car, its important to check for liens against the vehicle. Since if there is an outstanding debt on the car, then the buyer runs the risks of having it repossessed by the lender or the service provider. Thus we can say that knowledge of lien and its kinds is very important and as a customer it makes oneself aware and more knowledgeable.
“Redemption: the right to regain ownership of property by freeing it from a debt, charge, or lien (as by paying to the creditor what is due to release the secured property); specifically: a mortgagor’s statutory right to redeem after a judicial foreclosure and sale.”
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Q1. What is the meaning of Lien?
Q2. What is the applicability of the law related to lien?
Q3. What is the importance of Lien as a right?
Q4. What are the different kinds of Lien?
Q5. Whether any new provisions could be implemented or enforced upon?
Q6. Whether the topic has a wide scope?
Q7. What is the Literature available under this topic?