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If the contract of lease for the second year was treated as a separate contract and the land became unfit for the purposes of agriculture due to floods, then Clause (e) of Section 108 was directly applicable and no fault can be found with the decision. This being so, the observations that the doctrine of frustration is applicable even to leases, are more or less in the nature of an "obiter dictum". It is also to be noted that observations to the contrary, made by their Lordships of the Supreme Court in Satyabrata's case, AIR 1954 SC 44 that this doctrine was inapplicable to cases where an estate in land was created, were not even referred to in this Trav-Cochin case, (S) AIR 19,50 Trav-Co. 59.