PROMISSORY ESTOPPEL: ORIGIN, DEVELOPMENT AND APPLICABILITY AGAINST GOVERNMENTAL ACTIONS

By
MOHSIN MUMTAZ*

I.          A cursory glance at the concept of estoppel:-

Concept of promissory estoppel has emanated from the concept of estoppel. In order to comprehend the notion of promissory estoppel, it is imperative to bear in mind the basic principles and ideology of the concept of estoppel.

 The concept of Estoppel is based on the maxim, alleqans centraria non set audiendus (a person alleging contradictory acts should not be heard) and is that species of presumption jurts et de jure (irrebutable presumptions of law), where the fact presumed is taken to be true, not as against the world, but as against a particular party.

“The doctrine of estoppel is, in fact, an equitable doctrine, a rule of exclusion, which implies that if a person has, by act or omission altered his position, he will be estopped and be precluded or debarred from denying it or take a position so as to alter his position to the detriment of the other person, the opposite­ party”[1].

“Estoppe”, says Lord Coke, “cometh of the French word estoupe, from whence the English word stopped, and it is called an estoppel or conclusion, because a man’s own act or acceptance stoppeth or closet up his mouth to allege or plead the truth.”[2]

The foundation of the rule of estoppel is the equitable doctrine that, “it would be most inequitable and unjust to a person that if another, by a representation made, or by conduct amounting to a representation, has induced him to act as he would not otherwise have done, the person who made the representation should be allowed to deny or repudiate the effect of his formal statement, to the loss and injury of the person who acted on it”.[3]

The principle of estoppel is based on equity and good conscience and the object is to prevent fraud and secure justice between the parties by promotion of honesty and good faith and by preventing them from approbating and reprobating at the same time.[4]

II.        Promissory Estoppel: Origin of :-

The concept of promissory estoppel draws its roots from the concept of the broad rule of justice stated by Lord Carins[5]  by observing that, “It is the first principle upon which all Courts of Equity proceed, that if parties who ever entered  into definite and distinct terms involving certain legal results- certain penalties- or legal forfeiture afterwards by their own act or with their own consent upon a course  of negotiation which has the effect of leading one of the parties to suppose that the strict rights arising under the contract will not be enforced, or will be kept in  suspense, or held in abeyance, the person who otherwise might has enforced those rights will not be allowed to enforce them where it would be inequitable having regard to the dealings which have thus taken place between the parties”.

The principle had also been explained by Bowen LJ,[6] who observed that it was not confined to penalties and forfeitures but extended to all cases of contractual rights.

The concept of estoppel was so rigidly applied that it had given birth to certain harsh rules. One was that estoppel applied only in respect of; representations of fact, and not of statements of intention[7]. The other was that a representation, in order to work an estoppel, must be one of the fact and not of law.

The effect of these two factors was diluted in the case titled as Central London Property Trust Ltd v. The High Trees House Ltd.[8]

The facts were that during the war many people left London owning to the bombing. Flats were empty. In one block, where the flats were let on 99 year leases at € 2,500 per year, the landlord had agreed to reduce it by half and to accept € 1,250 a year. When the bombing was over, and the tenants came back, the landlord sought to recover the full € 2,500 a year. It was held that he could not recover it for the time when the flats were empty, Lord Denning wrote[9]:

          “As I have said they are not cases of estoppel in the strict sense. They are really promises – promises intended to be binding intended to be acted on, and in fact acted on. Jorden v Money can be distinguished, because there the promisor made it clear that she did not intend to be legally bound, whereas in the cases to which I refer the proper inference was that the promisor did intend to be bound. In each case the court held the promise to be binding on the party making it, even though under the old common law it might be difficult to find any consideration for it.”

          “The courts have not gone so far as to give a cause of action in damages for the breach of such a promise, but they refused to allow the party making it to act inconsistently with it. It is in that sense, and that sense only, that such a promise gives rise to an estoppel. The decisions are a natural result of the fusion of law and equity: for the cases of Hughes v Metropolitan Rly Co, Birmingham and District Land Co v London and North western Rly Co and Salisbury v Gilmore, afford a sufficient basis for saying that a party would not be allowed in equity to go back on such a promise to be recognized.”

          “The logical consequence no doubt, is that a promise to accept a smaller sum in discharge of a larger sum, if acted upon, is binding notwithstanding the absence of consideration: and if the fusion of law and equity leads to this result, so much the better. That aspect was not considered in Foakes v Beer ……………………………”

These historic words uttered by Lord Alferd Denning in the above mentioned case, were recognized.

III.       Development of Principle of Promissory Estoppel:-

The principle of promissory estoppel, right from its birth, started developing rapidly. As it mitigated the harshness of the strict application of the principle of estoppel, it came up for discussion in number of cases and was thereby refined resulting in the conceptual growth of the principle. 

In the High Trees case there was an actual promise or assurance. However, there were instances in cases involving sale of goods where conduct of the parties gave rise to some promise or assurance. Now question arose as to whether conduct was covered by the principle of promissory estoppels. In Charles Richards Ltd v Oppenhaim, Mr. Oppenhaim[10] wanted a body built on a chassis of a Rolls Royce ‘Silver Wraith’. In July 1947 the coachbuilders promised to deliver it ‘within six or at the most seven months’. They did not deliver it in that time. Mr. Oppenhaim still pressed them to deliver. They tendered delivery in June 1948 in accordance with his request, Mr. Oppenhaim refused to accept delivery? The question was, whether he could refuse to accept the delivery? Lord Denning M.R. delivered the judgment and held thus:

“If the defendant, as he did, led the plaintiffs to believe that he would not insist on the stipulation as to time, and that, if they carried out the work, he would accept it, and they did it, he could not afterwards set up the stipulation as to the time against them. Whether it be called waiver or forbearance on his part, or an agreed variation or substituted performance, does not matter, It is a kind of estoppel.”

“By his conduct he evinced an intention to affect, a promise not to insist on his strict legal rights. That promise was intended to be acted on it…… It is a particular application of the principle which I endeavored to state in Central London Property Trust Ltd v High Trees House Ltd.”

The verdict in Charles Richards Ltd v Oppenhaim proved to be a breakthrough. It laid down the principle that even if the parties adopt such conduct which gives necessary impression to the other party as if it were a promise or assurance that strict rights would not be enforced, the party making such promise by conduct would be bound by it.

The decision in High Trees case led many people to believe that the doctrine of consideration had been abolished to a great extent, in that, a promise was binding even if there was no consideration for it.  During the years since 1946 there had been much discussion about High Trees. This point needed elaboration. The same came up for decision in Combe v Combe[11]. The facts of the case were that on getting a divorce, a husband, by a letter of his solicitor, agreed to pay his wife an allowance of 100 pounds a year free of tax. The husband did not pay. She had a bigger income of her own than he did. After six years , she sued him for 600 pounds arrears. The judge at first instance had considered that the High Trees principle applied. But the Court of Appeal declined to extend it so. Lord Denning while sitting in King’s Bench held :

“………………………… That principle does not create new causes of action where none existed before. It only prevents a party from insisting upon his srtrict legal rights. When it would be unjust to allow him to enforce them, having regard to the dealings which have taken place between the parties. That is the way it was put in Hughes v Metroplitian Railway[12] , the case in the House of Lords in which the principle was first stated and in Birmingham etc Land Company v London and North Western Railway Co[13], the case in the court of Appeal where the principle was enlarged.”

“It is also implicit in all the modern cases in which the principle had been developed. Sometimes it is a plaintiff who is not allowed to insist on his strict legal rights. ………”

“On other occasions it is a defendant who is not allowed to insist on his strict legal rights. ………... It may be a part of a cause of action, but not a cause of action in itself …………”

“The principle , as I understand it , is that , where one party has, by his words or conduct, made to the other a promise or assurance which was intended to affect the legal relations between them and to be acted on accordingly , then , once the other party has taken him at his word and acted on it , the one who gave the promise or assurance cannot afterwards  be allowed to revert to the previous legal relations as if no such promise or assurance had been made by him, but he must accept their legal relations subject to the qualification which he himself has so introduced , even though it is not supported in point of law by any consideration but only by his word ……..”

“Seeing that the principle never stands alone as giving a cause of action in itself, it can never do away with the necessity of consideration when that is an essential part of the cause of action. The doctrine of consideration is too firmly fixed to be overthrown by a slide – wind. Its ill effects have been largely mitigated of late, but it still remains a cardinal necessity of the formation of a contract, though not of its modification or discharge ………………………………………………….”

Was it necessary for there to be a ‘detriment’ in order for High Trees to operate? Lord Denning, while delivering judgment in W.J. Alan & Co v El Nasar Export[14], replied in the negative. The operative part of the judgment reads:

“I know that it has been suggested in some quarters that there must be detriment. But I can find no support for it in the authorities cited by the judge …. If you study the cases in which the doctrine has been applied, you will see that all that is required is that the one should have ‘acted on the belief induced by the other party’. That is how Lord Cohen put it in the Tool Metal case[15], and that is how I would put it myself”.

This was accepted as correct by Mocatta J in Bremer v Vanden with approval of Lord Wilberforce in the House of Lords.

Before High Trees, even after 20 years of the decision therein, payment of a lesser sum was not designated as discharge of the complete debt. The effect of such a harsh principle was that if a merchant or tradesman, who owed a sum of money, was asked to take less, cash down, debtor pleading being in hot waters, then even if the creditor accepted the proffered sum he was not precluded by law institute a suit for recovery of a complete debt.

The law was so stated in 1602 by Lord Coke in Pinnel Case[16] and accepted in Foakes v Beer[17].

This principle was diluted in D and C Builders Ltd v Rees[18] wherein the Master of Rolls Lord Dennings held that, “when a creditor and a debtor enter upon a course of negotiation, which leads the debtor to suppose that , on payment of the lessor sum, the creditor will not enforce payment of the balance, and  on the faith thereof the debtor pays the lesser sum and the creditor accepts it as satisfaction : then the creditor will not be allowed to enforce payment of the balance when it would be inequitable to do so”.

Thus the development of the principle of promissory estoppels was marked by elimination of a rule which was causing injustice of its own kind.

IV.       Promissory Estoppel: Definitions:-

Having elucidated the origin and development of the concept, a few refined definitions of the notion of Promissory Estoppel need to be mentioned.  The principle has been defined[19] to mean that, “when one party has , by his own words or conduct made to the other a promise  or assurance which was intended to effect the legal relation between them and to be acted on accordingly , then once the other party has taken him at his word and acted on it, the one who gave the promise or assurance cannot afterwards be allowed to revert to their previous legal relations as if no such promise or assurance had been made by him , but he must accept their legal relations subject to the qualification which he himself  has so introduced”.

“Promissory estoppels proceeds on the footing that when on the representation of a promisor, a promisee alters his position, the former must keep his word and is not allowed to decade from his promise as otherwise it will work injustice on the latter”.[20]

Ingredients of promissory estoppel have been recognized to be[21]:

a.         “There is a clear and unequivocal promise by one party, through representation to the other party”, 

b.          ”The promisor expects, that the representation should reasonably expect to induce action or forbearance of a definite and substantial character on the part of the promise”,

c.          “The promise is intended to create a legal relationship to arise in the future”, and

d.         “Knowing or intending that it would be acted upon by the other party to whom the promise is made and it is in fact, so acted upon by the other party.”

In a Pakistani case[22] august Supreme Court of Pakistan has held that, “this doctrine has been variously called 'promissory estoppel' 'requisite estoppel', 'quasi estoppel' and 'new estoppel'. It is a principle evolved by equity to avoid injustice and though commonly named 'promissory estoppel'. it is neither in the realm of contract nor in the realm of estoppel. The true principle of promissory estoppel seems to be that where one party has by his words or conduct made to the other a clear and unequivocal promise which is intended to create legal relations or effect a legal relationship to arise in the future, knowing or intending that it would be acted upon by the other party to whom the promise is made and it is in fact so acted upon by the other party, the promise would be binding on the party making it and he would not be entitled to go back upon it, if it would be inequitable to allow him to do so having regard to the dealings which have taken place between the parties and this would be so irrespective of whether there is any pre‑existing relationship between the parties or not.”

“The rule of promissory estoppel being an equitable doctrine has to be molded to suit the particular situation. It is not a hard and fast rule but an elastic one, the objective of which is to do justice between the parties and to extend an equitable treatment to them. The doctrine should not be reduced to a rule of thumb. Being an equitable doctrine it should be kept elastic enough in the hands of the court to do complete justice between the parties”.[23]

Doctrine of promissory estoppel being an equitable principle evolved by courts for doing justice, it is not inhibited by the same limitations as estoppel in the strict sense of the term.[24]

However, at the same time, it is pertinent to observe that the doctrine of promissory estoppel has not been kept unfettered and there have been prescribed limitations for application of the same. The doctrine of promissory estoppel has been held[25] not to be available;

(i)         “against legislature in the exercise of its legislative functions”;

(ii)        “against the Government or public authority from enforcing statutory prohibition”;

(iii)      “to compel the Government or a public authority to honor a representation or promise which is contrary to law”;

(iv)       “to compel the Government or a public authority to carry out a representation or promise which was outside the authority of the officer of the Government or the public authority which made the representation”; and

(v)        having regard to the facts, if it appears that it would be inequitable to hold the Government or public authority to the promise or representation made by it”.

Doctrine of promissory estoppel has been applied against the governmental actions. Courts in England, USA, India and Pakistan have on numerous occasions held the government bound by the promises made by it by virtue of doctrine of promissory estoppel. Customs, income tax, import duties, educational institutions and policies thereof and service matters are few of the instances where the courts have held the government or government functionaries bound by their promises or representations where the non-application of the doctrine of promissory estoppel could have done injustice to the other persons.

V.         APPLICABILITY OF THE CONCEPT OF PROMISSORY ESTOPPEL AGAINST GOVERNMENT AND PUBLIC AUTHORITIES IN INDIA:-

The application of principle of promissory estoppel in India has been largely in the area of Governmental actions. Therefore, there is a catena of judicial dicta which have dealt with by the applicability or non-applicability of the doctrine of promissory estoppel in various areas of governmental activity. In order to grasp the judicial approach of Indian courts towards application of promissory estoppel against government, cases from Indian jurisdiction have been discussed below.

Before 1968, Indian Courts were not inclined to apply Doctrine of promissory estoppel against the Government. Amar Singh v. State of Rajasthan[26] is one of the instances where principle of promissory estoppel was refused to be applied against the Govt. 

However, the Indian Courts responded to the dynamic needs of the society and accepted the applicability of the doctrine of promissory estoppel against the government in Union of India v. Anglo Afghan Agencies[27]. In this case the Government of India announced certain concessions with regard to the import of certain raw materials in order to encourage export of woolen garments to Afghanistan. Subsequently, only partial concessions and not full concessions were extended as announced. The Supreme Court held that the Government was estopped by its promise.

The law relating to promissory estoppel has been liberally interpreted after the case of Motilal Padampat Sugar Mills v State of Uttar Pradesh[28]. In this case The High Court dismissed the writ petition and rejected the plea of promissory estoppel against the government. The Supreme Court, allowing the appeal held that, “where one party has by his words or conduct made to the other a clear and unequivocal promise which is intended to create a legal relationship or affect a legal relationship to arise in future, knowing or intending that it would be acted upon by the other party to whom the promise is made, and it is in fact so acted upon by the other party, the promise would be binding on the party making it and he would not be entitled to go back upon it”[29].

“It is indeed the pride of constitutional democracy and rule of law that the Government stands on the same footing as the private individual so far as the obligation of the law is concerned the former is equally bound as the latter. If the Government wants to resist the liability, it will have to disclose to the Court what are the subsequent events on account of which the Government claims to be exempt from the liability and it would be for the Court to decide whether those events are such as to render it inequitable to enforce the liability against the Government. Mere claim of change of policy would not sufficient to exonerate the Government from the liability, what precisely is the changed policy and also its reason and justification so the Court can judge for itself which way the public interest lies and what the equity of the case demands[30].”

However the case of Jit Ram Shiv Kumar v. State of Haryana[31] cast a shadow of doubt on the Motilal case whereby it was held that, “doctrine of estoppel is not available against the exercise of executive functions of the state”.  

The Supreme Court in Union of India v. Godfrey Phillips India Limited[32] soon removed this doubt. The Court held that, “the law laid down in Motilal case represents the correct law on promissory estoppel”.

The Court observed that “no doubt that the doctrine of promissory estoppel is available against the Government in the exercise of its Governmental, public or executive functions and the doctrine of executive necessity or freedom of future executive action cannot be invoked to defeat the applicability of the doctrine of promissory estoppel”[33].

In addition, the apex court also pointed out the limitations which the doctrine of promissory estoppel was applied subject to. It was held that “In India, the following limitations of the above doctrine are recognized and it has been held that in the following cases, the same shall not be available:‑‑(i) against legislature in the exercise of its legislative functions; (ii) against the Government or public authority from enforcing statutory prohibition; (iii) to compel the Government or a public authority to honor a representation or promise which is contrary to law; (iv) to compel the Government or a public authority to carry out a representation or promise which was outside the authority of the officer of the Government or the public authority which made the representation; and (v) having regard to the facts, if it appears that it would be inequitable to hold the Government or public authority to the promise or representation made by it.”

There is again a land mark judgment given by the Supreme Court in Express Newspaper Pvt. Limited v. Union of India[34], wherein the doctrine was applied to refrain the government from cancelling an action of the Minister granting lease as granting of the same was within his authority. Thus the fraud based on power was stemmed.

Thus, the Superior Courts in India have been applying the principle of Promissory Estoppel against Government and its functionaries in a wide range of cases.[35]

In a much recent pronouncement[36], the august Court of India summarized the latest position as to the application of doctrine of promissory estoppel and limitations thereto in the following words:

“32. The doctrine of promissory estoppel is by now well recognized and well defined by catena of decisions of this Court. Where the Government makes a promise knowing or intending that it would be acted on by the promisee and, in fact, the promisee, acting in reliance on it, alters his position, the Government would be held bound by the promise and the promise would be enforceable against the Government at the instance of the promisee notwithstanding that there is no consideration for the promise and the promise is not recorded in the form of a formal contract as required by Article 229 of the Constitution. The rule of promissory estoppel being an equitable doctrine has to be moulded to suit the particular situation. It is not a hard and fast rule but an elastic one, the objective of which is to do justice between the parties and to extend an equitable treatment to them. This doctrine is a principle evolved by equity, to avoid injustice and though commonly named promissory estoppel, it is neither in the realm of contract nor in the realm of estoppel. For application of doctrine of promissory estoppel the promisee must establish that he suffered in detriment or altered his position by reliance on the promise.”

“33. Normally, the doctrine of promissory estoppel is being applied against the Government and defence based on executive necessity would not be accepted by the Court. However, if it can be shown by the Government that having regard to the facts as they have subsequently transpired, it would be inequitable to hold the Government to the promise made by it, the Court would not raise an equity in favour of the promisee and enforce the promise against the Government. Where public interest warrants, the principles of promissory estoppel cannot be invoked. Government can change the policy in public interest. However, it is well settled that taking cue from this doctrine, the authority cannot be compelled to do something which is not allowed by law or prohibited by law. There is no promissory estoppel against the settled proposition of law. Doctrine of promissory estoppel cannot be invoked for enforcement of a promise made contrary to law, because none can be compelled to act against the statute. Thus, the Government or public authority cannot be compell to make a provision which is contrary to law.”

VI.       APPLICABLITY OF THE DOCTRINE OF PROMISSORY ESTOPPEL AGAINST GOVERNMENT IN PAKISTAN: JUDICIAL DICTA:

In Pakistan, as is the situation in India, doctrine of promissory estoppel has been strenuously applied against the government in exercise of its executive functions. The platform which has been used by Pakistani Courts to cling to the doctrine of promissory estoppel is the dicta in this regard laid down by Indian courts. Courts in Pakistan have applied the doctrine of promissory against the government where the circumstances so warranted and have rescued an individual person or company from injustice being done.

The basic case which envisioned the application of doctrine of promissory estoppel against government was in 1991[37]. In this case the facts were that the Government of Pakistan notified a scheme for import of second hand reconditioned machinery, which came to be known as N.R.I. Scheme. It was provided in the Scheme that import of second hand reconditioned machinery on repatriable basis would not require permission of any Government agency provided that the conditions contained therein were met. The respondent, acting upon the above Scheme, purchased certain second hand machinery in United Kingdom from his earning abroad. After submitting necessary documents, the respondent obtained no­-objection certificate from the Investment Promotion Bureau, Government of Pakistan, Ministry of Industries. When he applied for an import licence, in spite of his best efforts he was unable to obtain the same.

Consequently, he filed a constitutional petition in the High Court of Sindh for an order directing the Chief Controller of Imports and Exports, to issue the import licence, which was allowed. The Federation of Pakistan filed 4 petitions for leave to appeal, which inter alia included a petition for leave to appeal against the above judgment. Leave to appeal was granted by the Supreme Court to examine the legality of the judgments passed by The Learned High Court. The learned Deputy Attorney General representing the Federation of Pakistan contended that the doctrine of promissory estoppel did not extend to legislative, executive or sovereign functions of the State.

The Supreme Court repelled the said condition and observed as under: “[T]he contention is correct to the extent that doctrine of promissory estoppel does not indeed extend to legislative and sovereign functions, but executive actions are not excluded from the operation of the doctrine. The learned Deputy Attorney‑General has basically relied for his contention on the decision given in Ram Niwas Gupta and others v. State of Haryana through Secretary, Local Self Government, Chandigarh and another AIR 1970 Punjab and Haryana 462 which was approved by the Indian Supreme Court in the case of Messrs Jit Ram Shiv Kumar and others AIR 1980 SC 1285, but both these decisions were overruled by the Indian Supreme Court itself in Union of India and others v. Godfrey Philips India Limited AIR 1986 SC 806...” .

The Court went on to delineate the limitations of the principle:

“It may also be observed that at the same time, it was also highlighted that the doctrine of promissory estoppel was subject to the following limitations”:

(i)       “The doctrine of promissory estoppel cannot be invoked against the legislature or 'the laws framed by it because the legislature cannot make a representation”;

(ii)      “Promissory estoppel cannot be invoked for directing the doing of the thing which was against the law when the representation was made or the promise held out”;

(iii)     “No agency or authority can be held bound by a promise or representation not lawfully extended or given”;

(iv)     “The doctrine of promissory estoppel will not apply where no steps have been taken consequent to the representation or inducement so as to irrevocably commit the property or the reputation of the party invoking it”; and,

(v)      “The party which has indulged in fraud or collusion for obtaining some benefits under the representation cannot be rewarded by the enforcement of the promise”.

One year after the above mentioned judgment, the matter again came up for consideration before the apex court[38]. The facts of the case were that the appellants were engaged in manufacture of sugar. Their sugar mills were situated at various places in the Province of Sindh. The Federal Government, pursuant to the power contained in section 12‑A, of the Central Excises and Salt Act, 1944, issued a notification­ exempting certain goods from payment of central excise duty including sugar. The exemption relating to sugar was to be determined on the excess quantity produced by 'a factory as per formula contained in the above notification, excise duty would be charged on the concessional rates mentioned therein. The appellant, acting on the above representation, produced excess quantities but the above notification was rescinded. The matter was first agitated before the High Court without any success then it was brought before the Apex Court.

The Court took up the plea and summarized the law regarding applicability of the doctrine of promissory estoppel against government in many jurisdictions and held that:

          “If an exemption from payment of excise duty or any other tax, has been granted for a specified period on certain conditions and if a person fulfils those conditions, he acquires a vested right, he cannot be denied the exemption before the expiry of the specified period, through an executive instrument like a notification, but he can be denied his' vested right by a legislative provision.”[39] 

          “The doctrine of promissory estoppel is pressed into service in order to prevent the exercise of legal rights where it would be unconscionable for the possessor of those rights to do so[40].”

After going through all the concerned judgments and legislative provisions the Apex Court finally held that, “The doctrine of promissory estoppel is available in Pakistan against the Government and its functionaries, subject to inter alia limitations highlighted by one of us, Shafiur Rahnian, J., in the case of Pakistan v. Salahuddin (supra).”[41]

Ever since, the superior courts in Pakistan have applied the doctrine of promissory estoppel in a number of cases.[42] However, such application has not been unbridled and the application the doctrine of promissory estoppel has also been refused[43] if the circumstances of the case were such as attract any of the limitations mentioned before.

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*.        The author holds a Masters degree in Law and is a serving Civil Judge currently functioning at the Research Centre of the Lahore High Court, Lahore.

[1].       Gulfam v. Ali Muhammad, PLD 1989 Kar. 499.

[2].       Lancilot Feilding Everest, Everest and Storde’s Law of Estoppel (3rd Ed., 1923) p.1.

[3].       Haji Muhammad Younas v. Haji Muhammad Ismail, PLD 1959 Kar. 755.

[4].       Muhammad Fsar v. Muhammad Sharif, 1989 CLC 1850 see also  Durga Dass v. Sansar Singh,2003(1) PLJR666 (P&H).

[5].       Hughes v. Metropolitian Railway Co. Ltd. (1877) 2 AC 439.

[6].       Birmingham and District Land Co v London and NW Railway Co (1888) 40 Ch D 268.

[7].       Jorden v Money, (1845) 5 HL Cas 185.

[8].       [1947] 1 KB 130.

[9].       Ibid.

[10].      Charles Richards Ltd v Oppenhaim, Mr. Oppenhaim,  [1950] 1 KB 616, 623.

[11].      Combe v Combe,  [1951] 2 K.B. 215.

[12].      (1877) 2 AC 439.

[13].      (1888) 40 Ch D.

[14].      [1972] 2 Q.B. 189.

[15].      (1955) 1 WLR 761, 799.

[16].      (1602) 5 Co. Rep. 117.

[17].      (1884) 9 App Cas 605.

[18].      [1965] 2 QB 617.

[19].      Halsbury’s Law of England, 3rd Ed; Vol. 15, p.175, para 344.

[20].      Sh.kimti lal rahi v. union of india, AIR 1993 Del 211at p.217.

[21].      CRESCENT INDUSTRIAL CHEMICAL LTD v. FEDERATION OF PAKISTAN, PLD 2004 Quetta 92.

[22].      PAKISTAN through Ministry of Finance Economic Affairs v. FECTO BELARUS TRACTORS LIMITED, PLD 2002 Supreme Court 208.

[23].      M.C. Sarkar& S.C. Sarkar, Sarkar’s Law of Evidence (Sixteenth Edition, Wadha and CO. Nagpur 2007) vol. 2, p. 1934.

[24].      Mangalam Timber Products Ltd. V. State, AIR 1996 Ori. 13.

[25].      Messrs Army Welfare Sugar Mills Ltd Versus Federation of Pakistan, 1992 SCMR 1652.

[26].      Amar Singh v. State of Rajasthan [AIR 1955 SC 504].

[27].      Union of India v. Anglo Afghan Agencies, AIR 1968 SC 718.

[28].      Motilal Padampat Sugar Mills v State of Uttar Pradesh, AIR 1979 SC 621.

[29].      Motilal Padampat Sugar Mills v State of Uttar Pradesh, AIR 1979 SC 621.

[30].      Ibid.

[31].      Jit Ram Shiv Kumar v. State of Haryana,  AIR 1980 SC 1285.

[32].      Union of India v. Godfrey Phillips India Limited, AIR 1986 SC 806.

[33].      Ibid.

[34].      Express Newspaper Pvt. Limited v. Union of India, AIR 1986 SC 872.

[35].      See for instance: Assistant Commissioner of Commercial Taxes v. Dharamndra Trading Co., AIR 1988 SC 1247, Steel  Crackers v. M.S.T.C., AIR 1992 Cal 86: (1991) 1 Cal LT 491, Ude Ram. State of Haryana, AIR 1994 P & H 175 at 179-180., Bharat Explosives Ltd v. Yhe Pradeshiya Industrial & Investment Corporation  of U.P. Ltd, AIR 1994 All 123 at 133, Surendra Singh v. State of Uttar Pradesh 1991 LIC 1346 (DB), Prakash  Chand Dwivedi v. State of Utar Pradesh 1991LIC 2182, SASJN Inter College v.Secy Board HS & Intermediate Examination 1991All LJS, DDA v. Lala Amar Nat Educational Human Society AIR 1991Del 96, (1990) 42 Del LT 651 (DB), R Manjunath v. Indian Institute of technology AIR 1987 Mad 22, Davinder Singh v State of Jammu & Kashmir 1988 Kash LJ 127 (J 7 K), Rajendra Singh v Allahabad Development Authority 1987 All LJ 842, 1987 All WC 1305 (DB); Anakh Singh v state of Punjab AIR 1994 P&H 157, Kantilal v Chairman, Town Improvement Trust, Ratlam AIR 1986 MP 134, 1986 Cur CIV LJ 245, (1986) 1 Cur CC 434, 1986 Jab LJ (DB), Sardar Vallabhabhai Patel Memorial Society v State of Gujrat AIR 1984(NOC) 16 Guj, Tapti oil Industries v State AIR 1984 Bom 161 (para 23), 1984 Mah LJ 321, (1984) 86 Bom LR 67, Nihal Singh v Director of Education 1983 LIC 1662, (1983) 2 Serv LJ 332 (Del), Gujrat  State Financial Corp v M/S Lotus Hotels Pvt Ltd AIR 1983 SC 848, 1983 Guj LH 977, Ikop Laidakol Fishinf Co-op Society v State of  Manipur AIR 1982 Gau 14, Laxmi Film Lab v State (1986) 1 Guj LR 263 (GUJ), M/s Sri Jagannath Roller Flour Mill v State AIR 1986 0ri 163, (1986) 61 Cut LT 369 (DB), Mcdowell & Co Ltd v Union of India (1990) 45 ELT 236 (Bom), M/s Junghadra Sugar Works Pvt Ltd v Union of India AIR 1989 NOC 35 (Del) (DB), Poornima Oil Mills v State of Kerala AIR 1987 SC 590, 1986 JT (SC)1112; State of Bihar v Usha Martin Industries Ltd 1988 SCC (TAX) 116, STC ( Note) 430; Asst Comm, Commercial Taxes v Dharmendra Trading Co AIR 1988 SC 1247, (1988) 3 SCC 570, Real Estate Agency v Model Co-op Hsg Society (1990) 3 Bom CR 534 (DB), Food Corporation of India v M/s Babulal Agrawal AIR 2004 SC 2926, Dr Rita Rastogi v DDA (1991) 43 DLT 111 (Del) (DB), Bhim Singh v State of Haryana AIR 1980 SC 786, 1979 UJ (DC) 829., Maharaj v Chand (1986) 3 All ER 107 (PC), Government International Pvt Ltd v Union of India AIR 1991 Kant 52, State of Orissa v Mangalam Timber Products Ltd AIR 2004 SC 297, Pramodbhai v Officer on Special Duty No 2 (LA), Ahmedabad AIR 1989 Guj 187, American Dry Fruits Stores v Union of India (1990) 2 Bom CR 671, SKG Sugar Mills v State of Haryana 1975 BJLR 192, AIR 1975 Par 123, Maxey charan v.Rohilkhand University, Bareilly,AIR 1992 Del211 at p.217, Smita Shukla v. University of Allahabad, AIR 1994 NOC 107(All), Mohd Asif Iqbal v Vice Chancellor , Allahabad University 1989 All LJ 785 (ALL) Randhir Singh v State of Rajasthan (1995) I WLC 644 (Raj), K Narmada v Secy , Medical and Health Dept, Andhra Pradesh AIR 1988 AP 2, M Hussain v Bharathiya University , Coimbatoe AIR 1991 Mad 45, Smita Shukla v. University of Allahabad, AIR 1994 NOC 107 (All), Ashwin Prafulla Pimgalwar and etc. v. State of Mahrashtra,AIR1992 Bom 233 at pp.242, 244.

[36].      Shree Sidhbali Steels Ltd. Versus State of U.P. 2011 AIR (SC) 1175.

[37].      Pakistan through Secretary Ministry of Commerce and 2 others v, Salahuddin and 3 others, P L D 1991 SC 546.

[38].      Messrs Army Welfare Sugar Mills Limited and others v. Federation of Pakistan, 1992 SCMR 1652.

[39].      Messrs Army Welfare Sugar Mills Limited and others v. Federation of Pakistan, 1992 SCMR 1652.

[40].      Ibid.

[41].      Ibid.

[42].      See for instance: Khyber Plastic and Polymer Industries (Pvt.) Ltd v. Government of Pakistan (Ministry of Finance), 1997 PTD 1872; Messrs Excell Builders v. The Karachi Metropolitan Corporation, 1999 YLR 2659; Alcatel Pakistan Limited v. Collector of Customs, 1999 YLR 710; Lever Brothers Pakistan Ltd v. Government of Punjab, PLD 2000 Lah 1; Federation of G-6 Welfare Association, Islamabad v. Government of Pakistan, 2001 MLD 643; Messrs Lucky Cement Limited v. The Central Board of Revenue, PLD 2001 Pesh. 7; Rukhsar Ali v. Government of N.-W.F.P., 2003 PSC 1453; Messrs Friendship Textile Mills v. Government of Balochistan, 2004 SCMR 346.

[43].      See for example; Azra Riffat Rana v. Secretary, Minsitry of Housing and Works, Islamabad, 2008 PLC 995; Malik Muhammad Majeed v. Government of Pakistan; Petrosin Corporation (Pvt.) Ltd. Singapore v. Oil and Gas Development Company Ltd. through Managing Director, Islamabad, 2010 SCMR 306; Rubia Abrar v. Pakistan, 1993 MLD 1193; Mian Nazir Sons Industries Ltd. v. Government of Pakistan, 1992 SCMR 883, Abdul Wahid Abdul Majid v. Government of Pakistan, 1993 SCMR 17; Messrs Moin Sons (Pvt.) Ltd., Rawalpindi v. Capital Development Authority (CDA), Islamabad Capital Development Authority (CDA), Islamabad, 1998  PTD  2557; Polyron Ltd. v. Govt. of Pakistan, PLD 1999 Kar. 238.