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Fateh Chand vs Balkishan Das on 15 January, 1963

"But, as we have already mentioned, we do not propose to go into those aspects in the case on hand. As mentioned earlier, the appellants never raised any contention that the forfeiture of the amount amounted to a penalty or that the amount forfeited is so large that the forfeiture is bad in law. Nor have they raised any contention that the amount of deposit is so unreasonable and therefore forfeiture of the entire amount is not justified. The decision in Maula Bux's [1970]1SCR928 had no occasion to consider the question of reasonableness or otherwise of the earnest deposit being forfeited. Because, from the said judgment it is clear that this Court did not agree with the view of the High Court that the deposits made, and which were under consideration, were paid as earnest money. It is under those circumstances that this Court RFA No.1061/2017 Page 27 of 42 proceeded to consider the applicability of Section 74 of the Contract Act. (At page 143)"
Supreme Court of India Cites 7 - Cited by 574 - J C Shah - Full Document

Shree Hanuman Cotton Mills & Ors vs Tata Air-Craft Ltd on 28 October, 1969

"66. There is another aspect of the matter which cannot be lost sight of. If damages cannot be calculated and the terms of the contract provides therefor only for penalty by way of liquidated damages, having regard to the provisions contained in Section 74 of the Indian Contract Act a reasonable sum only could be recovered which need not in all situations even be the sum specified in the contract. (See Maula Bux vs. Union of India and Shree Hanuman Cotton Mills vs. Tata Air Craft Ltd.)
Supreme Court of India Cites 8 - Cited by 184 - C A Vaidyialingam - Full Document

Roshan Lal vs The Delhi Cloth And General Mills ... on 10 August, 1910

70. Forfeiture of earnest money under a contract for sale of property whether movable or immovable, if the amount is reasonable, would not fall within Section 74. That has been opined in several cases. (See Kunwar Chiranjit Singh v. Har Swarup; Roshan Lal v. Delhi Cloth and General Mills Co. Ltd.; Mohd. Habib-ullah v. Mohd. Shafi ; Bishan Chand v. Radha Kishan Das.) These cases have explained that forfeiture of a reasonable amount paid as earnest money RFA No.1061/2017 Page 32 of 42 does not amount to imposing a penalty. But if forfeiture is of the nature of penalty, Section 74 applies.
Allahabad High Court Cites 0 - Cited by 76 - Full Document

M/S. Kailash Nath Associates vs Delhi Development Authority & Anr on 9 January, 2015

These observations have cross-reference to Para 34 of the judgment of Kailash Nath Associates's case (supra) where with reference to the para of Fateh Chand's case (supra) it is held that the language of Section 74 of the Contract Act that 'whether or not damage or loss is proved to have been caused by breach' is the language that such language only discharges proof of actual loss but that does not justify award of compensation where in consequence of breach no injury/loss has at all resulted.
Supreme Court of India Cites 26 - Cited by 564 - R F Nariman - Full Document

Maula Bux vs Union Of India (Uoi) on 19 August, 1969

40. From the above, it is clear that this Court held that Maula Bux's case was not, on facts, a case that related to earnest money. Consequently, the observation in Maula Bux that forfeiture of earnest money under a contract if reasonable does not fall within Section 74, and would fall within Section 74 only if earnest money is considered a penalty is not on a matter that directly arose for decision in that case.
Supreme Court of India Cites 5 - Cited by 42 - J C Shah - Full Document
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