K. Hutchi Gowder vs H. Bheema Gowder on 6 January, 1959
In Hutchi Gowder v. Bheema Gowder, 1959-2 Mad LJ 324: (AIR 1960 Mad 33) the question was whether a covenant of further assurance should be enforced by directing the defendant to execute a release deed or a deed of conveyance, and the Court held that the defendant should execute a deed of conveyance. These decisions do not lay down that a deed styled a deed of release cannot, in law, transfer title to one who before the transfer had no interest in the property."