Review, Appeal, and Revision

The provisions related to Review, Appeal, and Revision form an important part of both civil and criminal procedures. They substantiate rights granted to the individuals to question the legality and propriety of their judgments. The need for the creation of these procedures was to ensure that justice is fairly delivered. Appeal means the removal of a cause from an inferior court to a superior one to test the soundness of the decision of the inferior court. Review of judgment is to look at or study the facts and judgment of the case once more and Revision means where a higher court calls for the record of the case decided by a court subordinate to it to check whether the jurisdiction, procedure, and legal principles were duly followed while disposing of the case.

Introduction

In India, the three tiers Judiciary i.e. District Courts, High Courts and Hon’ble Supreme Court of India has several roles and procedures to perform in delivering justice. The provision of appeal, review, and revision empowers all the three Courts to exercise such, depending on which Court’s Order is challenged. Therefore it is necessary to know the nature and scope of all the three provisions and also how they differ from each other. Any illegality, irregularity or impropriety coming to the notice can be rectified with the help of these mechanisms. To prevent the miscarriage of justice which defeats the very purpose of the judicial system, the need for the creation of some procedures is essential to ensure that justice is fairly delivered.

Review, Appeal, and Revision in Civil Cases

Review under Civil Cases, that is, Civil Procedure Code

The review is a provision under Section 114, which states:

Subject as aforesaid, any person considering himself aggrieved-

by a decree or order from which an appeal is allowed by this Code, but from which no appeal has been preferred,

by a decree or order from which no appeal is allowed by this Court, or

by a decision on a reference from a Court of Small Causes, may apply for a review of judgment to the Court which passed the decree or made the order, and the Court may make such order thereon as it thinks fit.

The word review refers to an act of carefully looking at or examining or inspecting the quality or condition of something or someone. As per Black’s Dictionary, a review is “to re-examine judicially; a reconsideration; second view or examination; revision; consideration for purposes of correction.” So, the review of a judgment is to look at or study the facts and judgment of the case once more. A review of a judgment is that the substantive power of the court provided under Section 114 of the Civil Procedure Code. This section doesn’t offer any limitations or conditions for review. The restrictions and conditions of review are provided under Order 47 of the Code. It contains 9 rules that impose some conditions for the review. The review is filed by the aggrieved in the same court where the order or decree is passed. It is a discretionary right of the court and not statutory right.

Review by the Supreme Court

Article 137 of the Constitution confers power on the Supreme Court to review its judgments subject to the provisions of any law made by Parliament or the Rules made under clause (c) of Article 145. The power of the Supreme Court, therefore, cannot be curtailed by the Code of Civil Procedure.

Cases where review lies (who can file a review)

  • The review can be filed by any person who feels himself to be deprived of rights or aggravated under the law or the rule of law under Rule 1 order 47 of the CPC.
  • Non-appealable cases– Non-appealable cases are cases where no right is given to the suffered party or when an appeal is rejected on the grounds of incompetence or being time-barred. The party who has suffered can hence file for review.
  • Where appeal lies but is not preferred– In cases where the benefit of an appeal lies but is not preferred by the party, the party can file for a review but the review must not be against the order because that would be going into the facts which are not entertained by the courts. When the party has already filed for an appeal before the court which is pending, in such cases the petition for review will not be entertained by the court. However, if the review petition is filed first and the appeal is filed subsequently then the court’s jurisdiction to review can’t be questioned under law.

What are the grounds of reviewing cases?

According to Section 114 of CPC, any person aggrieved by a decree or order from which an appeal is allowed but not filed, or a decree or order from which no appeal is allowed, can file a review petition in the same court which passed such decree or order on the following grounds:

  • Discovery of new evidence– When of new evidence or matter which is substantial to the case and was not in the cognizance of the concerned person, then that person can successfully apply for review. However, the burden of proof lies in the concerned person to prove that at the time of the verdict he was completely unaware of the fact or evidence that could influence the decision making. However, the mere fact that the concerned party was not cognizant of the ruling in any other case which might have impacted the decision wouldn’t be considered by the court for review.
  • Error on the face of record– The prima facie error that looks pretty conspicuous without a legal analysis of the judgment can only be taken into account for review under this ground. The error or mistake could either be a mistake in law or a mistake.
  • Other sufficient reason– This ground of review has given a very wide coverage of the reviewing process. In the landmark case of Chajju Ram v. Neki,[1] it was held that “the sufficient reason shall be connected with the other two reasons in the least possible way. The mere fact that the court ignored an important fact will not make a valid point under this ground.”

An appeal under Civil Procedure

Under CPC, 1908, Part VII is legislated on appeals comprising of sections 96 to 112, however, the word “appeal” is not defined under CPC. Appeal means the removal of a cause from an inferior court to a superior one to test the soundness of the decision of the inferior court. The superior court need not be High Court but maybe a District Court.

  • The appeal is a creature of statute.
  • An appeal is a proceeding where a higher forum reconsiders the decision of a lower forum, on

 (a) questions of fact;

 (b) questions of law, with jurisdiction to confirm, reverse, modify the decision or remand the matter to the lower forum for fresh decision in terms of its directions.

  • Appeal only against the decree, or appealable orders.
  • The right of appeal is substantive – Right to First appeal is a substantive right but the Second appeal is only allowed on a substantial question of law.  
  • An appeal abates if the legal representatives of a deceased party are not brought on the record within the time allowed by law.
  • In appeal questions of law and facts, both can be agitated.
  • Suo moto appeal is not possible.
  • The appeal is a continuation of the suit wherein the entire proceedings are left open before the appellate authority- Appeal is the continuation of the original proceedings before a superior court. The statutory right of appeal confers the right of re-hearing the whole dispute unless expressly restricted in scope and the appellate court is not confined to the reasons which have been given by the subordinate court for its decision.
  • Subsequent events can be considered by the appellate authority.

By Section 96 of CPC, an appeal lies against all decrees passed by a court in the exercise of original civil jurisdiction, except consent decree, and decree passed in a suit filed under Section (9) of the Specific Relief Act, and a final decree, the preliminary decree of which is not challenged. The appeal also lies against an order if so provided for by Section 104, or Order 43 CPC. As soon as judgment is pronounced against the party, the right to appeal arises. The right to appeal doesn’t arise when the adverse decision is given, but on the day suit is instituted i.e. proceedings commenced, right to appeal get conferred. Thus, it can be said the Right to appeal is appeal substantive right vested in parties from the date suit instituted.

Consent Decrees are not appealable

 In Punjab National Bank vs. Lakshmichand Rah[2], the Madhya Pradesh High Court held that “It may incidentally be further seen that even the Code of Civil Procedure does not provide for an appeal under Section 96(3) against a consent decree. The Code of Civil Procedure also intends that once a consent decree is passed by Civil Court finality is attached to it. Such finality cannot be permitted to be destroyed, particularly under the Legal Services Authorities Act, as it would amount to defeat the very aim and object of the Act with which it has been enacted; hence, we hold that the appeal filed is not maintainable.”

Who can appeal?

  1. Any party to the suit, who is adversely affected by the decree or the transferee of interest of such party, has been adversely affected by the decree provided his name was entered into the record of suit.
  2. An auction purchaser from an order in execution of a decree to set aside the same on the grounds of fraud.
  3. Any person who is bound by the decree and decree would operate res judicata against him and is permitted by the Appellate Court to file an appeal.

Revision under Civil Procedure

Revision means re-examining the case involving improper inference, non-exercise, or inappropriate jurisdictional exercise. Where no appeal lies for a case, which is decided by the subordinate court, Section 115 of the Code of Civil Procedure gives the High Court the power to revise the matter. This jurisdiction is known as the High Court’s revisional jurisdiction. Revision is the power of the High Court to revise the cases decided by the courts subordinate to it. The term “revision” is not defined under CPC. It is an optional power and not a compulsory one.

There are some conditions in which revisional jurisdiction is exercised. The case must be decided by the subordinate court. There should be no remedy of appeal to be exercised. In the case of  Major. S.S. Khanna v. Brig. F.J. Dillion[3], Supreme Court held that, when any other remedy is available, the court may not exercise its revisional jurisdiction.

In the exercise of revisional powers, it is not the responsibility of the High Court to take into consideration the benefits of the evidence; it merely has to see if the provisions of the law have been properly adhered to by the court whose order is the subject of the revision.

In Section 115 of the CPC, there are only three grounds for revision, which are: 

  • When the lower court meditates on a matter on which it has no jurisdiction.
  • There was authority, but it was not exercised.
  • Jurisdiction has been applied illegally or irregularly.

Section 115 shall thus prevent subordinate courts or lower courts from acting arbitrarily, illegally, irregularly, or capriciously.

The distinction between Review and Appeal

  • When appealing to a court superior to the one that issued the verdict, the appellant will contest the inferior court’s decision with an appeal. The appeal is a motion to be tried again. An appeal to ask the higher court to amend the lower court’s decision is sought. The lower court’s decision may remain the same or it may be revised by the higher court. A review is not people’s statutory right and is applicable at the court’s discretion. A review is applied in the same court in which the original decision is taken and is a request to consider the legality of the ruling. A review is based on irregularity of procedures, impropriety, irrationality, and illicitness.
  • There’s just one review. The second request for review does not lie. On the other hand, there are three appeals:
    • From District Munsiff Magistrate Court/Subordinate Judge’s Court to District Judges (First Appeal); 
    • From District Judge’s Court to the High Court(Second Appeal);
    • From the High Court to the Supreme Court (Third Appeal).
  • An appeal is referred to different judges whereas a review is referred to the same judge.
  • The grounds for appeal are wider in ambit than the ground for review.

Following judgments can be used to differentiate between appeal and revision:

  1. State of Kerala v. K.M. Charia Abdullah & Co., (1965) the Supreme Court observed:

“When the legislature confers a right of appeal in one case and a discretionary remedy of revision in another, it must be deemed to have created two jurisdictions different in scope and content. When it introduced the familiar concepts of appeal and revision, it is also reasonable to assume that the well-known distinction between these two jurisdictions was also accepted by the legislature. There is an essential distinction between an appeal and a revision. The distinction is based on differences implicit in the said two expressions. An appeal is a continuation of the proceedings; in effect, the entire proceedings are before the Appellate Authority and it has the power to review the evidence subject to the statutory limitations prescribed. But in the case of a revision, whatever powers the revisional authority may or may not have; it has not the power to review the evidence unless the statute expressly confers on it that power. That limitation is implicit in the concept of revision.” The same was reiterated in Lachhman Dass v. Santokh Singh, (1995).

  • Associated Cement Co. Ltd. v. Keshvanand, (1998)the Supreme Court held:

“It is a trite legal position that appellate jurisdiction is coextensive with original court’s jurisdiction as for appraisal and appreciation of evidence and reaching findings on facts and an appellate court is free to reach its conclusion on evidence untrammeled by any finding entered by the trial court. Revisional powers on the other hand belong to the supervisory jurisdiction of a superior court. While exercising revisional powers the court has to confine to the legality and propriety of the findings and also whether the subordinate court has kept itself within the bounds of its jurisdiction including the question of whether the court has failed to exercise the jurisdiction vested in it. Though the difference between the two jurisdictions is subtle, it is quite real and has now become well recognized in legal provinces.”

Difference between Review and Revision

  1.  Meaning

Review means to reconsider, to look again, or to re-examine. In a legal sense, it is a judicial re-examination of the case by the same court and by the same Judge.

Whereas Revision means the high court is revising the judgment of any case decided by a subordinate Court in certain circumstances. To correct or improve the judgment.

  1. Object

To rectify any error made in an order resulting in affecting the interest of a party. The same court and same judge review the judgment.

Whereas any illegality, irregularity or impropriety coming to the notice of High court has the jurisdiction to the High Court to examine the records relating to the ‘’any order’’ and/or proceedings is capable of being corrected by the High Court.

  • Grounds
  • Discovery of new and important matter or evidence. Such evidence must be: –
    (a) Relevant
    (b) Or of such character that if it had been given it might have altered the judgment.
  •  Mistake or error
  • Other sufficient reason

Whereas there is a case decided by a subordinate Court in which no appeal lies to the High Court.

 Subordinate Court while deciding a case appears to be: –

(a) to have exercised a jurisdiction not vested in it by law, or

(b) to have failed to exercise a jurisdiction so vested, or

(c) to have acted in the exercise of its jurisdiction illegally or with material irregularity

4. Conditions arise when

No right of appeal is allowed to an aggrieved party, he can file a review application.

Whereas No right of appeal is allowed to a party, he can file a revision application.  

Review, Revision, and Appeal in Criminal matters

  • Review and Revisionary Powers of Sessions Court and High Court

The legislators have incorporated the concept of review under the Code of Criminal Procedure, which is called “Revision” which has been provided under the Code to uphold the ultimate goal of the entire judicial system which is the deliverance of justice. Section 397 to Section 405 of the Code include the provisions concerning the revisionary jurisdiction granted to the higher courts and the procedure by which the higher courts exercise this jurisdiction guaranteed to it. The powers granted to the high courts are very wide and are completely discretionary.

Revision means where a higher court calls for the record of the case decided by a court subordinate to it to check whether the jurisdiction, procedure, and legal principles were duly followed while disposing of the case. Section 399 provides that a Sessions Court shall have the same revisionary powers as the High Court under Section 401 and the procedure to be followed by the Sessions Court is also the same. Therefore, the powers of the two courts are analyzed together under one common head.

Prerequisites to the Exercise of Revisionary Powers

  • Calling of Records of Case: The court, first of all, must call for the records of the case which is to be revised from the court which previously heard the matter. The records contain the FIR or Complaint, the Witness Statements recorded under Section 161 CrPC, the Confession recorded under Section 164 CrPC (if any), the deposition of witnesses before the court, their examination-in-chief and cross-examination, any documents brought on record and lastly, the original or certified copy of the judgment of the court from which the revision is intended.
  • Unsatisfaction of parties on the court’s judgment: Just like appeal, the revision of the judgment can be brought by either of the parties to the suit which is aggrieved by the judgment and the findings of the court. However, the court exercising the revisional jurisdiction cannot revise the judgment on its merit and only revise the procedural aspect of the judgment.

Discretionary Power

Section 401 states that the court may “in its discretion” exercise revisionary powers to grant relief to a party. The term discretion awards wide powers upon the courts to accept or refuse the revision of the judgment. The courts are required to use this discretion wisely and to ensure that justice is not hampered.

Revisionary powers allow the court to interfere with the decision of a lower and to rectify any error caused by it and it, therefore, is the first step to acquire the faith of people in the judiciary. If this power is misused or abused, the only remedy left is an appeal which requires huge time and expense of the parties.

Available Remedies under Revisionary Jurisdiction

The courts are entitled to use all powers and grant all remedies in their revisionary jurisdiction as provided under sections 386, 389, 390, and 391 of the CrPC. These remedies can be listed as follows:

  • If the revision petition is filed by the Prosecutor against an order of acquittal, the revisionary court may reverse the order of acquittal into conviction or order that the case is further investigated and if any evidentiary material is found, the accused be retried.
  •  If the revision is for an order of conviction filed by the accused person, the court may acquit the accused or order that a retrial is conducted and due procedure of law be followed.
  • The court, in a revision from conviction order, may also inquire upon the findings of the lower court on which the sentence is decided and may alter such sentence if necessary.
  • The court may, in an order of conviction, change the nature of the sentence imposed upon the accused by the lower court. It means that the revisionary court may alter a sentence of rigorous imprisonment to simple imprisonment.
  • If the revision is filed for the augmentation of the sentence imposed by the lower court, the court may change the sentence and enhance it according to the materials available.
  • When a person has filed an appeal against the conviction order of the lower court before an appellate court, the revisionary court may suspend the sentence of the accused till the appeal is disposed of and may enlarge the accused on bail.
  • If the revision is against an order of acquittal, the revisionary court may order to arrest the accused who was earlier released by the lower court. In such arrest, the accused have all the rights of an arrested person as guaranteed by the CrPC.

These are the remedies that can be sought in an application for the revision of a judgment of a trial court. Revisionary powers are enjoyed by Sessions Court and High Court but the nature and extent of the power are the same as aforementioned. A person can file a revision based on the court from the order of whose a revision is preferred.

An appeal under Criminal Cases

The word “appeal” has not been defined in the Code of Criminal Procedure, 1973; however, it can be described as the judicial examination of a decision given by a lower court by a higher court. The Merriam-Webster dictionary defines appeal as “a legal proceeding by which a case is brought before a higher court for review of the decision of a lower court”.

Except for the statutory provisions laid down by CrPC or any other law which is in force, an appeal cannot lie from any judgment or an order of a criminal court. Thus, there is no vested right to appeal as such as even the first appeal will be subjected to statutory limitations. The justification behind this principle is that the courts which try a case are competent enough with the presumption that the trial has been conducted fairly. However, as per the proviso, the victim has a right to appeal against any order passed by the Court under special circumstances comprising of a judgment of acquittal, a conviction for a lesser offense, or inadequate compensation.

When are the appeals filed?

Appeals are filed in the following cases:

  1. Appeals from conviction: where the accused is convicted and the trial is conducted by the high court then an appeal would lie to the Supreme Court. But if the trial is held by the session judge or additional session judge or any other court in which a sentence of imprisonment passed is more than 7 years then an appeal would lie to the high court.
  2. Appeal from orders requiring security or refusal to accept or rejecting surety for keeping the peace or good behavior: Any person, —

(i) who has been ordered under section 117 to give security for keeping the peace or for good behavior, or

(ii) who is aggrieved by any order refusing to accept or rejecting a surety under section 121, may appeal against such order to the Court of Session

Provided that nothing in this section shall apply to persons the proceedings against whom are laid before a Sessions Judge by the provisions of sub-section (2) or sub-section (4) of section 122.

  • Appeal by the state government against sentence: The State Government has been empowered by sec. 377 of CrPC to direct the Public Prosecutor to appeal against the sentence on the grounds of inadequacy to either the sessions court or the High Court, however in only those cases where the trial for conviction has not been held by the High Court.

Similarly, the District Magistrate and the State Government have the powers to direct the Public Prosecutor to present an appeal in case of an acquittal to Court of Sessions, and the High Court, respectively, subject to certain conditions. A two-Judge Bench of the Hon’ble Supreme Court held in the case of Satya Pal Singh v. State of Madhya Pradesh[4]  that the victim cannot file an appeal against an order of acquittal without obtaining the leave of the High Court.

If the conviction is done by the court other than a high court then state government but if such conviction is in a case wherein the offense has been investigated by the Delhi special police establishment or any agency under any central act then Central government can file the appeal-

  1. To the court of session, if the sentence is passed by the magistrate; and
  2. To the high court, if the sentence is passed by any other court

  What are the cases in which the appeal is not filed?

There are certain circumstances under which no appeal shall lie. These provisions have been laid down under Section 265G, Section 375, and Section 376 of the CrPC. They are as follows: –

  1. No appeal to lie if not provided by law – It is a general rule that the appeal is filed only when it is provided by the law. Section 372 says that “No appeal shall lie from any judgment or order of a criminal court except as provided for by this Code or by any other law for the time being in force”
  2. No appeal in petty Cases – Sec. 376 says that there shall be no appeal by the convicted person if

(a) where a High Court passes only a sentence of imprisonment for a term not exceeding six months or of fine not exceeding one thousand rupees, or of both such imprisonment and fine;

(b) where a Court of Session or a Metropolitan Magistrate passes only a sentence of imprisonment for a term not exceeding three months or of fine not exceeding two hundred rupees, or of both such imprisonment and fine;

(c) where a Magistrate of the first class passes only a sentence of fine not exceeding one hundred rupees; or

(d) wherein a case tried summarily, a Magistrate empowered to act under section 260 passes only a sentence of fine not exceeding two hundred rupees:

Provided that an appeal may be brought against such sentence if any other punishment is combined with it, but such sentence shall not be appealable merely on the ground—

(i) that the person convicted is ordered to furnish security to keep the peace; or

(ii) that a direction for imprisonment in default of payment of the fine is included in the sentence; or

(iii) that more than one sentence of fine is passed in the case if the total amount of fine imposed does not exceed the amount hereinbefore specified in respect of the case.

  • No appeal where the accused pleads guilty  – where an accused person has pleaded guilty and has been convicted on such plea, there shall be no appeal, —

(a) if the conviction is by a High Court; or

(b) if the conviction is by a Court of Session, Metropolitan Magistrate or Magistrate of the first or second class, except as to the extent or legality of the sentence.

 What are the powers of the appellate court?

The Appellate court has the following powers: –

  1. It has the power to dismiss the appeal if there is no sufficient ground for interfering in it
  2. It may reverse the order of the acquittal and direct the further inquiry or retry the accused and pass the sentence by the law.
  3. It may reverse, alter or maintain the order of conviction in an appeal
  4. It may enhance the sentence by reversing, altering the finding or altering the nature of the sentence
  5. It may make amendments or any consequential or incidental order that may be just or proper.

Generally, the same sets of rules and procedures are employed to govern the appeals in the Sessions Courts and High Courts (the highest court of appeal in a state and enjoys more powers in matters where the appeal is permissible). The highest court of appeal in the country is the Supreme Court and hence, it enjoys the most extensive discretionary and plenary powers in the cases of appeals. Its powers are largely governed by the provisions laid down in CrPC, Indian Constitution, and the Supreme Court (Enlargement of Criminal Appellate Jurisdiction), 1970.

The accused has been given the right to appeal to the Supreme Court against the judgment of the High Court if the High Court has reversed an order of his acquittal on appeal by convicting him, thereby, sentencing him to imprisonment for life or ten years or more, or death. Understanding the relevance of a criminal appeal being made to the Supreme Court, the same law has also been laid down in Article 134(1) of the Indian Constitution under the appellate jurisdiction of the Supreme Court. The Supreme Court (Enlargement of Criminal Appellate Jurisdiction) Act, 1970, has also been passed by the legislature in consonance with Article 134(2) of the Indian Constitution to confer additional powers on the Supreme Court to entertain and hear appeals from the High Court under certain conditions.

A similar right to appeal has been granted to one or all accused persons if more than one person has been convicted in a trial and such order has been passed by the court.

As to the finality of the judgments and orders passed on appeal, CrPC makes them final except in some cases. This shows how paramount importance is given to appeals.

Landmark Judgements

Smt. Ganga Bai v. Vijai Kumar[5]

There is a basic distinction between the right of the suit and the right of appeal. There is an inherent right in every person to bring a suit of a civil nature and unless the suit is barred by statute one may, at one’s peril, bring a suit of one’s choice.

But the position regarding appeals is quite the opposite. The right of appeal inheres in no one and therefore an appeal for its maintainability must have the clear authority of law.

Appeal only against a decree and not against the mere adverse finding.

Union Of India v. K.V. Lakshman [6]

  • The right to file the first appeal against the decree under Section 96 of the Code is a valuable legal right of the litigant.
  • The jurisdiction of the first appellate Court is very wide like that of the Trial Court and it is open to the appellant to attack all findings of fact or/and of law in the first appeal.
  •  The first appellate Court must appreciate the entire evidence and may conclude differently from that of the Trial Court.
  •  The first appeal is a valuable right of the parties and unless restricted by law, the whole case therein is open for rehearing both on questions of fact and law.

Madhukar And Ors v. Sangram [7]

  • The judgment of the Appellate Court must reflect its conscious application of mind, and it should record findings supported by reasons, on all the issues arising along with the contentions put forth, and pressed by the parties.
  •  While reversing a finding of fact the Appellate Court must come into close quarters with the reasoning assigned by the trial court and then assign its reasons for arriving at a different finding.
  •  This would satisfy the Court hearing a further appeal that the First Appellate Court had discharged the duty expected of it.”

Shasidhar v.  Ashwini Uma Mathod [8]

  • The first appellate court is expected to decide appeal keeping in view the scope and powers conferred on it. Failure to do so would be causing prejudice to the appellant whose valuable right to prosecute the first appeal on facts and law would be adversely affected which, in turn, deprived him of a hearing in the appeal by law.

Conclusion

The object of these provisions is the same only the procedure differs. The process of review and revision is given to a person to rectify any impropriety, illegality of order; similarly, the process of appeal gives a person the right of appearing before the court and getting any factual or legal error ratified by the court to attain justice. Thus to seek fair redressal and just determination of obligations these secondary rights are provided by law.

Frequently Asked Questions (FAQs)

  • What are the grounds of reviewing cases given under CPC?
  • As per the provisions of CPC who can file a review?
  • What are the powers of the appellate court?
  • Essentials for the Exercise of Revisionary Powers

References


  • [1] Chajju Ram vs Neki, (1922) 24 BOMLR 1238.
  • [2] Punjab National Bank vs. Lakshmichand Rah AIR 2000 Madhya Pradesh.
  • [3] Major. S.S. Khanna v. Brig. F.J. Dillion,1964 AIR 497.
  • [4] Satya Pal Singh v. State of Madhya Pradesh, CRIMINAL APPEAL NO. 1315 OF 2015.
  • [5] Smt. Ganga Bai v. Vijai kumar, AIR 1974 SC 1126.
  • [6] Union Of India v. K.V. Lakshman ,  AIR 2016 SC 3139.
  • [7] Madhukar And Ors v. Sangram,  AIR 2001 SC 2171.
  • [8] Shasidhar v.  Ashwini Uma Mathod , AIR 2015 SC 1139.

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