{"id":237751,"date":"1983-07-16T00:00:00","date_gmt":"1983-07-15T18:30:00","guid":{"rendered":"https:\/\/www.legalindia.com\/judgments\/mohit-kumar-jain-vs-income-tax-officer-on-16-july-1983"},"modified":"2015-07-02T23:07:00","modified_gmt":"2015-07-02T17:37:00","slug":"mohit-kumar-jain-vs-income-tax-officer-on-16-july-1983","status":"publish","type":"post","link":"https:\/\/www.legalindia.com\/judgments\/mohit-kumar-jain-vs-income-tax-officer-on-16-july-1983","title":{"rendered":"Mohit Kumar Jain vs Income-Tax Officer on 16 July, 1983"},"content":{"rendered":"
Income Tax Appellate Tribunal – Delhi<\/div>\n
Mohit Kumar Jain vs Income-Tax Officer on 16 July, 1983<\/div>\n
Equivalent citations: 1983 6 ITD 119 Delhi<\/div>\n
Bench: R Segel, Rajendra<\/div>\n<\/p>\n
<\/pre>\n
ORDER<\/p>\n
Rajendra, Accountant Member<\/p>\n
1.  These appeals are disposed of by a consolidated order, as a common point is involved in these appeals regarding applicability of Section 64(1)(iv), (v) and (vi) of the Income-tax Act, 1961 (‘the Act’) in respect of transfers for inadequate consideration by the appellants (assessees) to their relations covered by the said clauses.\n<\/p>\n
2. The assessees are close relatives. They were promoters of Electra India (P.) Ltd. and Electra (Jaipur) (P.) Ltd. All the three assessees hold shares in these private limited companies which they have transferred at face value to their relations specified in the aforesaid clauses of Section 64(1). The question is whether the transfer of shares at face value is for adequate consideration because the aforesaid clauses of Section 64(1) would apply only if it is held that the transfers were otherwise than for adequate consideration.\n<\/p>\n
 In the case of Mohit Kumar Jain, who had transferred shares to his sons in Electra India (P.) Ltd. at face value, the ITO noted that the assessee himself in the wealth-tax return on valuation dates on 31-3-1975 and 31-3-1976 had shown the value of shares in Electra India (P.) Ltd., at Rs. 204 and Rs 341 per share, respectively, and that the higher market value  as compared to face value was supported by the fact that   there had been issue of bonus shares by the said company on 11-11-1976 and 10-11-1978. He, accordingly, held that the transfer by the assessee to his minor sons on 26-3-1975 and 8-5-1975 was not for adequate consideration. He, accordingly, added Rs. 2,040 as dividend income of the assessee (out of dividend income of Rs. 4,000 declared on the transferred shares in the assessment year 1980-81).\n<\/p>\n
3.  In the case of Ajay Kumar Jain where the transfer of shares in Electra (Jaipur) (P.) Ltd. were to the assessee’s wife Anjula Jain on 7-11-1975 and to minor sons Anuj Jain on 29-3-1980, the ITO noted that the assessee in the wealth-tax  return for valuation date of 31-3-1975 had declared the value of shares in the said company at the rate of Rs. 155 per share  (the ITO has  not  mentioned the value declared by the assessee in the wealth-tax returns for the assessment years 1979-80 and 1980-81 which would be relevent in the case of the transfer of shares to the minor son).   The ITO, accordingly, treated Rs. 757 as dividend attributable to inadequate consideration (out of Rs.  2,000 being dividend declared in respect of the transferred shares in the assessment year 1980-81).\n<\/p>\n
4.  In the case of Ami Chand Jain where the transfer was of 300 shares  of Electra (Jaipur)  (P.)  Ltd.  to the  assessee’s son’s  wife on 23-6-1976, the ITO noted that the asse ssee on valuation date  of 31-12-1975  had  shown the market value of shares at Rs. 155 per share.    He,  accordingly, treated Rs. 1,705 and  Rs.   1,136  as dividend attributable to inadequate consideration (out of dividend of Rs. 3,000 each declared on the transferred shares for the assessment years 1979-80 and 1980-81).\n<\/p>\n
5.  The AAC in identical orders upheld the orders of the ITO in the cases of the three assessees.\n<\/p>\n
6.  At the hearing before us the learned Counsel for the assessees urged that as the purchases   by   the   three   assessees   of shares in the aforesaid two companies were at face value, the transfers by them to their specified relations at face value was not for inadequate consideration.   We are  unable to accept this contention.    The cost of acquisition by  the assessees has no relevance   for   considering   the   question   whether the transfers were for adequate consideration. If the transfers are not for adequate consideration, which has to be judged from the  angle  of market value  on the date of transfer, then the provisions of Section 64(1) would apply. We have already pointed out above that the three assessees in their wealth-tax returns had themselves declared the market value of shares at figures much higher than the face value of the shares. The learned Counsel has filed before us charts showing break up value  of the shares in the two companies on different valuation dates.    These charts show that the market value  of the  shares declared by the  assessees were based on the break up value of the shares. It is, thus, clear that the transfer of shares on their face value by the three assessees to their specified relations were otherwise than for adequate consideration. It has been held that the transfer should be for adequate consideration, i.e., consideration equal or nearly equal to the value of the assets transferred in order that Section 64 may not apply–Tulsidas Kilachand v. CIT [1961] 42 ITR 1 (SC) (see Kanga and Palkhivala’s Law and Practice of Income-tax, Volume 1, 7th edition, page 604).\n<\/p>\n
7.  The learned Counsel for the assessees relied on CGT v. Cawasji Jehangir Co. (P.) Ltd. [1977] 106 ITR 390, 398 (Bom.) where it was observed that in order that the Court may   hold   that a   particular transfer is not for adequate consideration, the difference between the true value of the property transferred,   and   the   consideration   that   passed   for the same, must be appreciable.   The Court further observed that adequate consideration cannot be construed with precision.   We have already noted  above that there was appreciable difference between the market value of the shares transferred by the three assessees and the consideration received,  namely, the face value of the shares.\n<\/p>\n
8.  The learned Counsel   for   the   assessee   next  relied  on CWT v. Bejoy Kumar Karnani [1979] 117 ITR 543 (Cal.).    In that case the  Court was dealing with the valuation of shares of an investment company and  observed that the value of unquoted shares should be determined on the basis of the average earning capacity   of the company. This case is clearly distinguishable as we are not dealing with the shares in an investment company. Even otherwise we notice that Electra India (P.)  Ltd.   declared  dividends ranging from 10 per cent to   15 per cent in the years under consideration and the asset backing of the   said  company  showed that the market value of the shares was much more than their face value of Rs. 100 each.\n<\/p>\n
9.  The assessee next relied on CGT v. In do Traders & Agencies  (Madras) (P.) Ltd. [1981] 131 ITR 313, 321 (Mad.).   In that case the Court observed that unless the price was   such  as to shock the conscience of the Court, it would not be possible to hold that the transaction  is  otherwise   than for adequate  consideration.    We  have  already  noted  above  that there was appreciable  difference  between the market price of the transferred shares and the face value of the  shares.    The market price of the  shares was around twice   the   face   value   of the shares on the date of transfer and, therefore, there was an appreciable difference between the consideration for the transfer and the market price of the transferred shares.\n<\/p>\n
10.  The assessee next relied on CIT v.   K.K.  Birla  [1982]   137  ITR 126 (Cal.). In   that   case  assessee’s   transfer  of shares to his wife at price of Rs. 4.22 per share as against the purchase price paid  by the   assessee of Rs. 4.12 per share was held to be for adequate consideration.  In that case, the Tribunal had found that the said  company had not declared any dividends   and, therefore,   the   fair   market   price   of the shares had to be determined on the basis of break up value of the  shares  on  the  date  of transfer (which has been done in the cases in appeal before us). The Tribunal had further found that there were serious restrictions on the transfer of impugned shares in the private limited company as the shares could be transferred only to the specified relations of the members of the company as indicated on page 131 of K.K. Birla’s case (supra). In view of those special circumstances, the High Court held that the transfer was for adequate consideration. However, the facts in the cases before us are clearly distinguishable because in the two companies under consideration, there are no similar restrictions on the transfers. Restrictions imposed by Clause 23 of the articles of association of Electra (Jaipur) (P.) Ltd. and Clause 39 of Electra India (P.) Ltd. are normal clauses which appear even in the articles of public limited companies which is to the effect that the directors can decline to register transfer of shares in their discretion.\n<\/p>\n
11.  We have already noticed above that the Calcutta High  Court in K.K. Birla’s case (supra)   approved the Tribunal’s determination of fair market value of the shares on the  basis of break up value of the shares.   This is exactly what has been done in the cases before us.\n<\/p>\n
12.  The Supreme Court in Tulsidas Kilachand's case (supra) construed adequate consideration as excluding love  and affection which may be good consideration but is not adequate consideration.    The Bombay High Court in CIT v. Vivian Bose [1979] 118   ITR  989 went over the case law on the point of adequate consideration.\n \n\n13.  We have carefully considered the facts of the cases, submissions of the parties and the case law and we hold that the transfers by the three asses-sees to their relations  were not for adequate consideration and,  therefore, the provisions of Section 64(1) were rightly  applied in their cases.   The assessees have not addressed us on the quantum of addition  under Section 64.    We have, therefore, not gone into it.\n \n\n14.  In the result the orders  of lower  authorities  are confirmed and the appeals are dismissed.\n\n \n\n<\/pre>\n","protected":false},"excerpt":{"rendered":"
Income Tax Appellate Tribunal – Delhi Mohit Kumar Jain vs Income-Tax Officer on 16 July, 1983 Equivalent citations: 1983 6 ITD 119 Delhi Bench: R Segel, Rajendra ORDER Rajendra, Accountant Member 1. These appeals are disposed of by a consolidated order, as a common point is involved in these appeals regarding applicability of Section 64(1)(iv), […]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_lmt_disableupdate":"","_lmt_disable":"","_jetpack_memberships_contains_paid_content":false,"footnotes":""},"categories":[1],"tags":[],"class_list":["post-237751","post","type-post","status-publish","format-standard","hentry","category-judgements"],"yoast_head":"\nMohit Kumar Jain vs Income-Tax Officer on 16 July, 1983 - Free Judgements of Supreme Court & High Court | Legal India<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/www.legalindia.com\/judgments\/mohit-kumar-jain-vs-income-tax-officer-on-16-july-1983\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Mohit Kumar Jain vs Income-Tax Officer on 16 July, 1983 - Free Judgements of Supreme Court & High Court | Legal India\" \/>\n<meta property=\"og:url\" content=\"https:\/\/www.legalindia.com\/judgments\/mohit-kumar-jain-vs-income-tax-officer-on-16-july-1983\" \/>\n<meta property=\"og:site_name\" content=\"Free Judgements of Supreme Court & High Court | Legal India\" \/>\n<meta property=\"article:publisher\" content=\"https:\/\/www.facebook.com\/LegalindiaCom\/\" \/>\n<meta property=\"article:published_time\" content=\"1983-07-15T18:30:00+00:00\" \/>\n<meta property=\"article:modified_time\" content=\"2015-07-02T17:37:00+00:00\" \/>\n<meta property=\"og:image\" content=\"https:\/\/i0.wp.com\/www.legalindia.com\/judgments\/wp-content\/uploads\/sites\/5\/2025\/09\/legal-india-icon.jpg?fit=512%2C512&ssl=1\" \/>\n\t<meta property=\"og:image:width\" content=\"512\" \/>\n\t<meta property=\"og:image:height\" content=\"512\" \/>\n\t<meta property=\"og:image:type\" content=\"image\/jpeg\" \/>\n<meta name=\"author\" content=\"Legal India Admin\" \/>\n<meta name=\"twitter:card\" content=\"summary_large_image\" \/>\n<meta name=\"twitter:creator\" content=\"@legaliadmin\" \/>\n<meta name=\"twitter:site\" content=\"@Legal_india\" \/>\n<meta name=\"twitter:label1\" content=\"Written by\" \/>\n\t<meta name=\"twitter:data1\" content=\"Legal India Admin\" \/>\n\t<meta name=\"twitter:label2\" content=\"Est. reading time\" \/>\n\t<meta name=\"twitter:data2\" content=\"8 minutes\" \/>\n<script type=\"application\/ld+json\" class=\"yoast-schema-graph\">{\"@context\":\"https:\\\/\\\/schema.org\",\"@graph\":[{\"@type\":\"Article\",\"@id\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/mohit-kumar-jain-vs-income-tax-officer-on-16-july-1983#article\",\"isPartOf\":{\"@id\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/mohit-kumar-jain-vs-income-tax-officer-on-16-july-1983\"},\"author\":{\"name\":\"Legal India Admin\",\"@id\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/#\\\/schema\\\/person\\\/0bfdffe9059fb8bb24a86d094609c5ea\"},\"headline\":\"Mohit Kumar Jain vs Income-Tax Officer on 16 July, 1983\",\"datePublished\":\"1983-07-15T18:30:00+00:00\",\"dateModified\":\"2015-07-02T17:37:00+00:00\",\"mainEntityOfPage\":{\"@id\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/mohit-kumar-jain-vs-income-tax-officer-on-16-july-1983\"},\"wordCount\":1455,\"commentCount\":0,\"publisher\":{\"@id\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/#organization\"},\"articleSection\":[\"Judgements\"],\"inLanguage\":\"en-US\",\"potentialAction\":[{\"@type\":\"CommentAction\",\"name\":\"Comment\",\"target\":[\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/mohit-kumar-jain-vs-income-tax-officer-on-16-july-1983#respond\"]}]},{\"@type\":\"WebPage\",\"@id\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/mohit-kumar-jain-vs-income-tax-officer-on-16-july-1983\",\"url\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/mohit-kumar-jain-vs-income-tax-officer-on-16-july-1983\",\"name\":\"Mohit Kumar Jain vs Income-Tax Officer on 16 July, 1983 - Free Judgements of Supreme Court & High Court | Legal India\",\"isPartOf\":{\"@id\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/#website\"},\"datePublished\":\"1983-07-15T18:30:00+00:00\",\"dateModified\":\"2015-07-02T17:37:00+00:00\",\"breadcrumb\":{\"@id\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/mohit-kumar-jain-vs-income-tax-officer-on-16-july-1983#breadcrumb\"},\"inLanguage\":\"en-US\",\"potentialAction\":[{\"@type\":\"ReadAction\",\"target\":[\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/mohit-kumar-jain-vs-income-tax-officer-on-16-july-1983\"]}]},{\"@type\":\"BreadcrumbList\",\"@id\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/mohit-kumar-jain-vs-income-tax-officer-on-16-july-1983#breadcrumb\",\"itemListElement\":[{\"@type\":\"ListItem\",\"position\":1,\"name\":\"Home\",\"item\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/\"},{\"@type\":\"ListItem\",\"position\":2,\"name\":\"Mohit Kumar Jain vs Income-Tax Officer on 16 July, 1983\"}]},{\"@type\":\"WebSite\",\"@id\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/#website\",\"url\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/\",\"name\":\"Free Judgements of Supreme Court & High Court | Legal India\",\"description\":\"Search and read the latest judgements, orders, and rulings from the Supreme Court of India and all High Courts. A comprehensive database for lawyers, advocates, and law students.\",\"publisher\":{\"@id\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/#organization\"},\"alternateName\":\"Free judgements of Supreme Court & High Court of India | Legal India\",\"potentialAction\":[{\"@type\":\"SearchAction\",\"target\":{\"@type\":\"EntryPoint\",\"urlTemplate\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/?s={search_term_string}\"},\"query-input\":{\"@type\":\"PropertyValueSpecification\",\"valueRequired\":true,\"valueName\":\"search_term_string\"}}],\"inLanguage\":\"en-US\"},{\"@type\":\"Organization\",\"@id\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/#organization\",\"name\":\"Judgements of Supreme Court & High Court | Legal India\",\"alternateName\":\"Legal India\",\"url\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/\",\"logo\":{\"@type\":\"ImageObject\",\"inLanguage\":\"en-US\",\"@id\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/#\\\/schema\\\/logo\\\/image\\\/\",\"url\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/wp-content\\\/uploads\\\/sites\\\/5\\\/2025\\\/09\\\/legal-india-icon.jpg\",\"contentUrl\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/wp-content\\\/uploads\\\/sites\\\/5\\\/2025\\\/09\\\/legal-india-icon.jpg\",\"width\":512,\"height\":512,\"caption\":\"Judgements of Supreme Court & High Court | Legal India\"},\"image\":{\"@id\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/#\\\/schema\\\/logo\\\/image\\\/\"},\"sameAs\":[\"https:\\\/\\\/www.facebook.com\\\/LegalindiaCom\\\/\",\"https:\\\/\\\/x.com\\\/Legal_india\"]},{\"@type\":\"Person\",\"@id\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/#\\\/schema\\\/person\\\/0bfdffe9059fb8bb24a86d094609c5ea\",\"name\":\"Legal India Admin\",\"image\":{\"@type\":\"ImageObject\",\"inLanguage\":\"en-US\",\"@id\":\"https:\\\/\\\/secure.gravatar.com\\\/avatar\\\/4faa9d728ed1af3b73d52225c7f12901ac726fe6f7ea0a3348a1d51f3a930987?s=96&d=mm&r=g\",\"url\":\"https:\\\/\\\/secure.gravatar.com\\\/avatar\\\/4faa9d728ed1af3b73d52225c7f12901ac726fe6f7ea0a3348a1d51f3a930987?s=96&d=mm&r=g\",\"contentUrl\":\"https:\\\/\\\/secure.gravatar.com\\\/avatar\\\/4faa9d728ed1af3b73d52225c7f12901ac726fe6f7ea0a3348a1d51f3a930987?s=96&d=mm&r=g\",\"caption\":\"Legal India Admin\"},\"sameAs\":[\"https:\\\/\\\/www.legalindia.com\",\"https:\\\/\\\/x.com\\\/legaliadmin\"],\"url\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/author\\\/legal-india-admin\"}]}<\/script>\n<!-- \/ Yoast SEO plugin. -->","yoast_head_json":{"title":"Mohit Kumar Jain vs Income-Tax Officer on 16 July, 1983 - Free Judgements of Supreme Court & High Court | Legal India","robots":{"index":"index","follow":"follow","max-snippet":"max-snippet:-1","max-image-preview":"max-image-preview:large","max-video-preview":"max-video-preview:-1"},"canonical":"https:\/\/www.legalindia.com\/judgments\/mohit-kumar-jain-vs-income-tax-officer-on-16-july-1983","og_locale":"en_US","og_type":"article","og_title":"Mohit Kumar Jain vs Income-Tax Officer on 16 July, 1983 - Free Judgements of Supreme Court & High Court | Legal India","og_url":"https:\/\/www.legalindia.com\/judgments\/mohit-kumar-jain-vs-income-tax-officer-on-16-july-1983","og_site_name":"Free Judgements of Supreme Court & High Court | Legal India","article_publisher":"https:\/\/www.facebook.com\/LegalindiaCom\/","article_published_time":"1983-07-15T18:30:00+00:00","article_modified_time":"2015-07-02T17:37:00+00:00","og_image":[{"width":512,"height":512,"url":"https:\/\/i0.wp.com\/www.legalindia.com\/judgments\/wp-content\/uploads\/sites\/5\/2025\/09\/legal-india-icon.jpg?fit=512%2C512&ssl=1","type":"image\/jpeg"}],"author":"Legal India Admin","twitter_card":"summary_large_image","twitter_creator":"@legaliadmin","twitter_site":"@Legal_india","twitter_misc":{"Written by":"Legal India Admin","Est. reading time":"8 minutes"},"schema":{"@context":"https:\/\/schema.org","@graph":[{"@type":"Article","@id":"https:\/\/www.legalindia.com\/judgments\/mohit-kumar-jain-vs-income-tax-officer-on-16-july-1983#article","isPartOf":{"@id":"https:\/\/www.legalindia.com\/judgments\/mohit-kumar-jain-vs-income-tax-officer-on-16-july-1983"},"author":{"name":"Legal India Admin","@id":"https:\/\/www.legalindia.com\/judgments\/#\/schema\/person\/0bfdffe9059fb8bb24a86d094609c5ea"},"headline":"Mohit Kumar Jain vs Income-Tax Officer on 16 July, 1983","datePublished":"1983-07-15T18:30:00+00:00","dateModified":"2015-07-02T17:37:00+00:00","mainEntityOfPage":{"@id":"https:\/\/www.legalindia.com\/judgments\/mohit-kumar-jain-vs-income-tax-officer-on-16-july-1983"},"wordCount":1455,"commentCount":0,"publisher":{"@id":"https:\/\/www.legalindia.com\/judgments\/#organization"},"articleSection":["Judgements"],"inLanguage":"en-US","potentialAction":[{"@type":"CommentAction","name":"Comment","target":["https:\/\/www.legalindia.com\/judgments\/mohit-kumar-jain-vs-income-tax-officer-on-16-july-1983#respond"]}]},{"@type":"WebPage","@id":"https:\/\/www.legalindia.com\/judgments\/mohit-kumar-jain-vs-income-tax-officer-on-16-july-1983","url":"https:\/\/www.legalindia.com\/judgments\/mohit-kumar-jain-vs-income-tax-officer-on-16-july-1983","name":"Mohit Kumar Jain vs Income-Tax Officer on 16 July, 1983 - Free Judgements of Supreme Court & High Court | Legal India","isPartOf":{"@id":"https:\/\/www.legalindia.com\/judgments\/#website"},"datePublished":"1983-07-15T18:30:00+00:00","dateModified":"2015-07-02T17:37:00+00:00","breadcrumb":{"@id":"https:\/\/www.legalindia.com\/judgments\/mohit-kumar-jain-vs-income-tax-officer-on-16-july-1983#breadcrumb"},"inLanguage":"en-US","potentialAction":[{"@type":"ReadAction","target":["https:\/\/www.legalindia.com\/judgments\/mohit-kumar-jain-vs-income-tax-officer-on-16-july-1983"]}]},{"@type":"BreadcrumbList","@id":"https:\/\/www.legalindia.com\/judgments\/mohit-kumar-jain-vs-income-tax-officer-on-16-july-1983#breadcrumb","itemListElement":[{"@type":"ListItem","position":1,"name":"Home","item":"https:\/\/www.legalindia.com\/judgments\/"},{"@type":"ListItem","position":2,"name":"Mohit Kumar Jain vs Income-Tax Officer on 16 July, 1983"}]},{"@type":"WebSite","@id":"https:\/\/www.legalindia.com\/judgments\/#website","url":"https:\/\/www.legalindia.com\/judgments\/","name":"Free Judgements of Supreme Court & High Court | Legal India","description":"Search and read the latest judgements, orders, and rulings from the Supreme Court of India and all High Courts. A comprehensive database for lawyers, advocates, and law students.","publisher":{"@id":"https:\/\/www.legalindia.com\/judgments\/#organization"},"alternateName":"Free judgements of Supreme Court & High Court of India | Legal India","potentialAction":[{"@type":"SearchAction","target":{"@type":"EntryPoint","urlTemplate":"https:\/\/www.legalindia.com\/judgments\/?s={search_term_string}"},"query-input":{"@type":"PropertyValueSpecification","valueRequired":true,"valueName":"search_term_string"}}],"inLanguage":"en-US"},{"@type":"Organization","@id":"https:\/\/www.legalindia.com\/judgments\/#organization","name":"Judgements of Supreme Court & High Court | Legal India","alternateName":"Legal India","url":"https:\/\/www.legalindia.com\/judgments\/","logo":{"@type":"ImageObject","inLanguage":"en-US","@id":"https:\/\/www.legalindia.com\/judgments\/#\/schema\/logo\/image\/","url":"https:\/\/www.legalindia.com\/judgments\/wp-content\/uploads\/sites\/5\/2025\/09\/legal-india-icon.jpg","contentUrl":"https:\/\/www.legalindia.com\/judgments\/wp-content\/uploads\/sites\/5\/2025\/09\/legal-india-icon.jpg","width":512,"height":512,"caption":"Judgements of Supreme Court & High Court | Legal India"},"image":{"@id":"https:\/\/www.legalindia.com\/judgments\/#\/schema\/logo\/image\/"},"sameAs":["https:\/\/www.facebook.com\/LegalindiaCom\/","https:\/\/x.com\/Legal_india"]},{"@type":"Person","@id":"https:\/\/www.legalindia.com\/judgments\/#\/schema\/person\/0bfdffe9059fb8bb24a86d094609c5ea","name":"Legal India Admin","image":{"@type":"ImageObject","inLanguage":"en-US","@id":"https:\/\/secure.gravatar.com\/avatar\/4faa9d728ed1af3b73d52225c7f12901ac726fe6f7ea0a3348a1d51f3a930987?s=96&d=mm&r=g","url":"https:\/\/secure.gravatar.com\/avatar\/4faa9d728ed1af3b73d52225c7f12901ac726fe6f7ea0a3348a1d51f3a930987?s=96&d=mm&r=g","contentUrl":"https:\/\/secure.gravatar.com\/avatar\/4faa9d728ed1af3b73d52225c7f12901ac726fe6f7ea0a3348a1d51f3a930987?s=96&d=mm&r=g","caption":"Legal India Admin"},"sameAs":["https:\/\/www.legalindia.com","https:\/\/x.com\/legaliadmin"],"url":"https:\/\/www.legalindia.com\/judgments\/author\/legal-india-admin"}]}},"modified_by":null,"jetpack_featured_media_url":"","jetpack_sharing_enabled":true,"jetpack_likes_enabled":true,"jetpack-related-posts":[],"_links":{"self":[{"href":"https:\/\/www.legalindia.com\/judgments\/wp-json\/wp\/v2\/posts\/237751","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/www.legalindia.com\/judgments\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/www.legalindia.com\/judgments\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/www.legalindia.com\/judgments\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/www.legalindia.com\/judgments\/wp-json\/wp\/v2\/comments?post=237751"}],"version-history":[{"count":0,"href":"https:\/\/www.legalindia.com\/judgments\/wp-json\/wp\/v2\/posts\/237751\/revisions"}],"wp:attachment":[{"href":"https:\/\/www.legalindia.com\/judgments\/wp-json\/wp\/v2\/media?parent=237751"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/www.legalindia.com\/judgments\/wp-json\/wp\/v2\/categories?post=237751"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/www.legalindia.com\/judgments\/wp-json\/wp\/v2\/tags?post=237751"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}