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“11. There is however, no warrant for the assumption made
by some of the High Courts in India, that Section 74 applies only to
cases where the, aggrieved party is seeking to receive some amount
on breach of contract and not to cases where upon breach of
contract an amount received under the contract is sought to be
forfeited. In our judgment the expression “the contract contains any
other stipulation by way of penalty” comprehensively applies to
every covenant involving a penalty whether it is for payment on
breach of contract of money or delivery of property in future, or for
forfeiture of right to money or other property already delivered.
Duty not to enforce the penalty clause but only to award reasonable
compensation is statutorily imposed upon courts by Section 74. In
all cases, therefore, where there is a stipulation in the nature of
penalty for forfeiture of an amount deposited pursuant to the terms
of contract which expressly provides for forfeiture, the court has
jurisdiction to award such sum only as it considers reasonable, but
not exceeding the amount specified in the contract as liable to
forfeiture.