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Pandit Suraj Narain vs Pandit Ratan Lal on 30 January, 1917

The learned Judges themselves felt the difficulty on account of the pronouncement of their Lordships of the Privy Council in Suraj Narain v. Ratan Lal A.I.R. 1917 P.C. 12, already referred to, and felt that in that case "apparently a contrary view was taken." They however remarked that that case was decided under the old Section 317, Civil P.C., the wording of which differed materially from that of Section 66. The difference in the wording which would be relevant was however not quoted. As far as can be seen the alteration in the language of the new section would make no difference so far as the point under consideration was concerned. One of the learned Judges remarked:
Bombay High Court Cites 1 - Cited by 19 - Full Document

Babu Deonandan Prasad Singh vs Janki Singh And Ors. on 30 March, 1920

7. It is urged before us that their Lordships intended to lay down that the rights of persons who are otherwise beneficially interested in the purchase can never be affected by the provisions of the section. We think that their Lordships intended to protect the interest of persons beneficially interested in the property purchased, other than those who claim to have made auction-purchases, who are not entitled to maintain the suit contrary to the provisions of Section 66. Further, the title of persons otherwise beneficially interested would not be affected; and if by some means they obtain possession of the property and are sued as defendants, Section 68 would not stand in their way as their title has in no way been destroyed. The next case relied upon on behalf of the appellant is the case in Deonandan Prashad v. Janki Singh A.I.R. 1916 P.C. 227. That was a special case not arising under the Civil Procedure Code. There, under the terms of his mortgage, a usufructuary mortgagee was liable to pay a certain amount of Government revenue. He had on a previous occasion paid an excess amount which however was somehow absorbed. Later he made a deposit which was short by Rs. 2-10-0. Their Lordships agreed with the Courts in India that the Government revenue had been deliberately allowed to fall into arrear with a view to the property being put up for sale and bought by the mortgagee. Although the mortgagee himself being a minor could not be considered to have been a party to the fraud, it was found that his agents had deliberately committed default in. breach of the terms of the mortgage. When the property was sold and purchased in the name of the mortgagee, their Lordships held that the mortgagee could not be allowed to hold for himself the advantage gained by the default for which his agents were responsible and that the advantage gained by the scheme must be held for the benefit of the co-owners who were not shown to have been aware of the default or sale, or to have disentitled themselves to the equitable relief. The sale had not taken place in execution of any decree, but for recovery of revenue under the provisions of Act 11 of 1859, and the case was really governed by Section 90, Trusts Act. Illus. (c) to that section was directly in point:
Patna High Court Cites 1 - Cited by 38 - Full Document
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