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CONTRA PROFERENTEM: AN IN-DEPTH ANALYSIS OF IT’S HISTORICAL EVOLUTION, PRINCIPLES, AND IMPACT ON INDIAN CONTRACT LAW
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CONTRA
PROFERENTEM: AN IN-DEPTH ANALYSIS OF IT’S HISTORICAL EVOLUTION, PRINCIPLES, AND
IMPACT ON INDIAN CONTRACT LAW
AUTHORED BY
- GULNAR ARORA
INTRODUCTION
Contract drafting is a prevalent
activity, and the issue of interpretation inevitably arises. The interpretation
of contracts is a requisite aspect in the realm of law. Typically, “commercial contracts
between parties are guided by business considerations, mutual rights and
obligations, and industry practices. The involved parties strive to clearly
outline their rights and obligations to prevent potential challenges in the
future.”[1]
Competency to Contract, mutual consent, lawful consideration, legal object, and
absence of void declarations are all essential elements of a valid contract.[2]
These elements establish the foundation for a free contractual relationship,
reducing the likelihood of disputes.
When drafting a contract, the person
creating it i.e., the drafter “must consider both statutory regulations that
may apply and address the specific needs of the situation.”[3]
This involves describing the “transaction, rights, representations, warranties,
covenants, and more in detail for each party.”[4] To
prevent ambiguity, drafters can incorporate interpretation guidelines into the
contract. They need extensive knowledge of legal precedents, statutory
regulations, and traditional drafting techniques. However, crafting an ideal contract,
especially in commercial scenarios with significant financial implications, is
a complex and challenging process. Even more, enforcing such contracts in case
of disputes can be an expensive and intricate legal procedure. When disputes
arise, courts resort to interpreting contract contents to address gaps.
CONTRACT
INTERPRETATION
Interpreting contracts commonly
begins with understanding the shared intent of the parties. When interpreting a
contract, the initial consideration is whether the provision is ambiguous.
Ambiguity occurs when it can reasonably be understood in more than one way.[5]
“Some courts take an objective stance, evaluating whether the provision is
reasonably open to multiple interpretations when read by someone in the
parties' position. Additionally, certain courts consider a reading of the
provision by an individual familiar with the customs, practices, and
terminology commonly understood in a specific trade or business.”[6]
However, there's a potential exception to this. If the plain meaning of a word
allows only one reasonable interpretation, that interpretation takes
precedence. It emphasizes that the contract should be examined in the context
of the circumstances under which it was made.
Furthermore, when faced with two interpretations,
the court typically avoids adopting an interpretation that leads to an absurd
result. It's crucial to note that a provision is not automatically deemed
ambiguous just because the parties disagree on its construction or propose
alternative interpretations. This nuanced approach aims to ensure a more
precise understanding of contractual terms and intentions.[7] In
determining whether a provision is ambiguous, the court must examine the entire
provision as a cohesive unit. The interpretation should avoid rendering any
provision or term meaningless, emphasizing the need for harmonization and
contextual reading of terms. Contracts executed simultaneously and with a
shared purpose should be construed and interpreted together. This comprehensive
approach ensures coherence and meaningful interpretation of contractual
provisions.
“There are many substantive rules
which are not supposed to enforce the parties’ intentions, actual or
hypothetical, rather they set limits to freedom of contract. Similarly, while
contract interpretation has the parties’ bargain at least as its ultimate goal,
in some cases the purpose of contract interpretation is not to find and give
effect to the intentions of the parties but to achieve other goals.”[8]
“Rule of Contra Proferentem” is one such rule of interpretation.
This principle is encapsulated in the Latin maxim “verba cartarum fortius
accipiuntur contra proferentem” which emphasizes constructing words against
those who employ them. The rule of Contra Proferentem means “the clause or
language or words in a contract would be interpreted against the party which
authored or introduced it.”[9]
The primary aim of the rule against the drafter is straightforward and
well-known: it deters ambiguity.[10]
Originating in the 17th century in the case of “Manchester College v
Trafford (1679), Lord Coke popularized it with his statement: It is a maxim
in law, that every man’s grant shall be taken by construction of law most
forcibly against him.”[11]
HISTORICAL DEVELOPMENT
OF CONTRA
PROFERENTEM
RULE
Within the Roman Legal system,
numerous principles of interpretation are embedded in their civil codes. One
guideline suggests that terms should be understood in the context of the entire
contract, while another emphasizes interpreting contracts to uphold all terms
rather than nullifying some of them.[12]
These principles originate from Roman law, compiled in Justinian's Digest and
extensively discussed in the late Middle Ages and the early modern era. The
foundation of Roman legal thought during this period was significantly
influenced by Greek philosophy, particularly dialectics and rhetoric.[13]
In legal systems, “Art. 1162 of the
French Civil Code, 1804 embodies the Contra Stipulatorem rule, tracing
its origin to the Roman jurist Celsus.”[14]
This rule, found in various legal systems globally, including common law
jurisdictions and Romanistic legal families, dictates that in case of
ambiguity, a contract term should be interpreted against the drafter
introducing it in a dispute. Used for consumer protection, especially in
standard form contracts, it is recognized in numerous legal instruments
regulating consumer contracts.[15]
As per a contemporary American
analyst, “this rule is not actually one of interpretation, because its application
does not assist in determining the meaning that the two parties gave to the
words, or even the meaning that a reasonable person would have assigned to the
language used. It is chiefly a rule of policy, generally favoring the
underdog.”[16] In case
of doubt, “an agreement shall be interpreted against the one who has
stipulated, and in favor of the one who has contracted the obligation.”[17]
“Later on, during classical Roman
legal times, some less formal contracts, like sales contracts (emptio-venditio)
and various contracts involving labor, services, leases, and rentals
(locatio-conductio), emerged. These contracts often included essential terms,
accompanied by additional agreements specifying extra provisions, usually
formulated by the vendor. The interpretative presumption “contra
venditorem/locatorem”, found in a few Digest rules, worked against the
drafter of ambiguous pacta. Roman jurists Papinianus and Paulus justified this
presumption, stating that the vendor could have spoken more clearly.”[18]
Yet, these were disjointed concepts discovered in the Digest, lacking any
indication of practical implementation during those times.[19]
During the Middle Ages, amidst
significant shifts in contract law doctrine and theory, the two principles, “ambiguitas
contra stipulatorem” and “ambiguitas contra venditorem/locatorem”,
underwent generalization and acquired the common name: “ambiguitas contra
proferentem”, which translates to "when in doubt, against the
drafter." Nevertheless, “the idea of "contra proferentem"
was introduced as a component of the general rule of interpretation. This was
aimed at addressing ambiguous language in deeds and contracts. The individual
drafting the document typically safeguarded their own interests, often
neglecting or overlooking the concerns of the other party involved.”[20]
Throughout these historical periods, the rule served as a final recourse.
“In the sixteenth century, Lord Sir
Edward Coke, a former Chief Justice in the King's Bench, England, introduced
the concept of "Contra Proferentem" in the English common law system.
Francis Bacon further developed this concept as an interpretative tool to
clarify obscurities and ambiguities in deeds, determining which conflicting
expressions in a document would be legally valid. Subsequently, William
Blackstone combined earlier rules with contemporary practices, aiming to
discourage unfair conduct by parties and prevent deceptive practices involving
ambiguous and indeterminate expressions in contracts.”[21]
APPLICATION
OF THE RULE CONTRA PROFERENTEM
David Ibbetson notes that “the common
law has a tendency to shed outdated rules but struggles to abandon entire
doctrines or bodies of ideas.”[22]
The contra proferentem rule is a prime example of this phenomenon, representing
a relic from an older era of contracting. Despite numerous reconceptualization
in contractual interpretation and the nature of contracts, the essence of the
rule persists into the twenty-first century. This concept comes into play when
a term in a contract is unclear, and it's introduced by the drafter of that
specific clause. In simpler terms, “the Contra Proferentem principle is
applied only when it's evident that a party has either drafted a confusing term
in a contract or has significantly contributed to its drafting.”[23]
“The literal translation of the
principle is the words of documents are to be taken strongly against the one
who puts forward. This could mean:
1.
The
person who prepared the document as a whole;
2.
The
person who prepared the particular clause;
3.
The
person for whose benefit the clause operates.”[24]
Different ways in which the rule of “Contra
Proferentem” could function:
1.
“Whoever
holds the pen creates the ambiguity and must live with the consequences.”[25]
The person who drafts the contract is responsible for any ambiguity that arises
in the contract's terms. The responsibility for interpreting and addressing
ambiguities in the contract falls upon the drafter.
2.
This
principle is frequently applied in Insurance Contracts. In “Houghton
v.Trafalgar Insurance Co Ltd.[26],
it was held that in case of ambiguity in the policy, it will be read in favor
of assured as the clause was supplied by the Insurer.”
3.
“This
concept may not be applicable when it is challenging to determine the party
presenting the terms or when both parties are equally identified as presenters.
Similarly, if the contractual terms are based on a standardized form developed
by an industry body and adopted by the parties, this concept will not be invoked.”[27]
4.
“After
objectively examining the document, the individual identified as presenting or
putting forward the terms would be considered the 'proferens.' In all
instances, interpretations of deeds should be construed against the grantor.”[28]
5.
In
the case of “Savil Brothers Ltd. v. Betheel[29],
the Court observed that in case of grant with an exception embedded therein,
the exception will be construed to benefit the grantor and accordingly the
grant will be read in favor of the grantee.”
6.
“Wherever
there is a doubt in any term of the contract and if such term is likely to
benefit or in favor of a party to the contract, it should be read against him.
This was observed in the case of Burton v. English.”[30]
7.
As
observed in “CDV Software Entertainment AG v. Gamecock Media Euroe Ltd[31],
this maxim may not be of much help or any use in case of mutually negotiated
commercial transactions.”
8.
“Contra
Proferentem principle will be used only when there is a real ambiguity in a
document. It should not be used for creation of any ambiguity where there was
none.”[32]
The “Contra Proferentem” Rule
can take two forms of interpretation:
1.
In
the first, contractual language may work against a party seeking to evade basic
liability or common law duties imposed independently of the contract.
2.
In
the second type, if there's unclear language in the contract, it will be held
against the party proposing that language.[33]
Both scenarios often come into play
concerning exclusion of liability clauses, allowing a party to escape
contractual obligations. “Such clauses, known as exemption, exception,
exculpatory, or limiting clauses, are introduced by either party in a contract
to anticipate and address potential hindrances or failures in performance.”[34]
“The primary goal is to accommodate consequences arising from non-performance,
partial performance, or negligent performance of the contract.”[35]
However, there's a fundamental distinction in how the wording is approached
between the two types. In the second case, it serves as a last resort rule when
ambiguity arises, while in the first type, it may be enforced if the language
in an "exclusion clause" is unambiguous. The first type typically
applies to exemption clauses, while the second type is relevant when unclear
language is proposed by the party relying on it.[36]
Nevertheless, as per certain
academics, exclusion clauses undergo a restricted interpretation and are
regarded as an independent principle of interpretation.[37]
Interpretations of "exclusion clauses" can arise even when clearly
expressed, and they are considered as a distinct rule. However, their
connection is undeniable due to a shared history. In instances where exclusion
clauses are clearly worded, they will not be subject to the rule of contra
proferentem.
APPLICATION
OF THE RULE CONTRA
PROFERENTEM
IN INDIA
In the context of Indian laws, there
are minimal statutory provisions guiding contract interpretation, primarily
emphasizing reasonableness and discouraging exploitation, particularly when
there is an imbalance in bargaining power between parties, leading to potential
ambiguity in contract interpretation rules.
“The Indian Contract Act, 1872,
outlines principles related to enforceability, void contracts, acceptance,
consent, fraud, and breaches. However, it lacks specific provisions or guidance
on contract drafting and interpretation.”[38]
Many people view Indian contract laws as outdated, with statutes scattered
across different legislations, diminishing the Act's overall clarity. In
addition to the Indian Contract Act, 1872 other relevant laws governing
contracts in India include the Sale of Goods Act, 1930, and the Indian Evidence
Act, 1872. “The Indian Evidence act strictly condemns ambiguous writing in a
contract, urges the drafter to use clear and unambiguous phrasing of the terms,
and requires a party disputing any terms of a contract, that are drafted using
plain and unambiguous language, to substantiate its claim that the phrasing of
such terms is actually meant to have a more liberal or vaguer meaning.”[39]
“Additionally, under Section 91 of
the Indian Evidence Act, a document stands as proof on its own, and no
alternative secondary evidence is permissible. Section 92 prohibits the
admission of oral evidence when the terms of a contract are established through
a document.”[40]
However, exceptions apply if evidence invalidating the document is presented,
or in cases of separate oral agreements, customary practices related to the
contract, or facts illustrating the language's manner.
Apart from established contract
interpretation principles, Indian courts, influenced by Common law traditions,
have incorporated the “Contra Proferentem” principle in various cases.
Notably, this principle has found application in the context of “insurance
contracts”. “Due to the insured party's obligation under the doctrine of “Uberremi
Fidei” (utmost good faith), the Contra Proferentem principle is
invoked against insurance companies when ambiguities arise in their policy
contracts.”[41]
JUDICIAL
INTERPRETATION OF THE RULE CONTRA PROFERENTEM BY INDIAN COURTS
As per Halsbury’s Laws of England[42], “the
principle of contra proferentem only becomes operative where the words are
truly ambiguous; it is a rule for resolving ambiguity and it cannot be invoked
with a view to creating a doubt. Therefore, where the words used are free from
ambiguity in the sense that, fairly and reasonably construed, they admit of
only one meaning, the rule has no application.”
The court highlighted this fact in “United
India Insurance Co. Ltd v. M/S. Orient Treasures Pvt. Ltd.[43]
and accordingly held that there was no ambiguity in the words expressed in the
clauses under dispute and the language carried only one meaning set out in
clear terms, the maxim was found not useful to decide the case. It was also
observed by the court “that when the words of a statute are plain or
unambiguous, the Courts are bound to give effect to the meaning irrespective of
the consequences.”
Similarly, in “M/s. I.P. &
Investment Corpn. v. New India Assuance Co Ltd.,[44]
it was held that in order to permit a claim under the policy a forcible and
violent entry would be required as sine qua non. However, the language was very
clearly set out in the insurance policy and admits of no ambiguity and hence
the question of invocation of the maxim does not arise in the case. This rule
cannot be used to find ambiguity or vagueness where it does not exist. The
words have to be read as it is without addition or subtraction.”
However, the Supreme Court observed
in the case of “Rashtriya Ispat Nigam Ltd. v. Dewan Chand Ram Saran[45]
that this principle will not apply and not to be invoked in commercially
negotiated contract between two parties.”
The Court in “General Assurance Society
Ltd. v. Chandmull Jain and Anr.[46],
and United Insurance Co. Ltd. v. M/S. Pushpalaya Printers[47]
observed that the Contracts of insurance being special standard contracts
requiring commitment of uberrima fides (good faith) on the part of the insured.
Hence, whenever there is an ambiguity in the contract, it was ruled against the
insurance company using the maxim of contra proferentem. Wherever the
facts fitted in this structure, the Supreme Court has applied the maxim to
those cases.”
Applying the principle of “contra
proferentem”, Delhi High Court in “Namrata Singh & Ors. V. Director
General Civil Aviation[48],
allowed the pilots to be eligible for the insurance cover on account of the
clear single language arrived at after reading the entire document and
concluded that the expression passengers included the pilots as well.”
“In Bank of India v. K. Mohandas
& Ors[49]. Supreme Court observed that the true
construction of a contract must depend upon the import of the words used and
not upon what the parties choose to say afterwards. Nor does subsequent conduct
of the parties in the performance of the contract affect the true effect of the
clear and unambiguous words used in the contract. The Court held that the banks
which framed the policy for Voluntary Retirement Scheme should take the
responsibility for any laxity in drafting leading to ambiguity in the
expression of the terms of the contract of retirement. Such ambiguity should
justifiably be held in favor of the optees of the scheme applying the rule of
contra proferentem.”
In a very recent case “Sushilben
Indravadan Gandhi v. The New India Assuarnace Company[50],
the Supreme Court considered the application of contra proferentem principle.
It held that only in the event of vagueness or unclear expressions used in a
clause, can the maxim be pressed into service. Upon examination of the clause,
if the ambiguity is found, then this maxim can be made applicable. Upon reading
of the entire insurance contract, if it brought about clarity, then in that
case even an ambiguous clause found in the contract the principle of contra
proferentem would not be applicable. Similarly, even if one meaning is given to
a clause but other parts of the insurance contract are clear, it would be
construed in accordance with the rest of the policy.”
IMPACT ON
INDIAN CONTRACT LAW: ANALYSIS
The principle of “contra
proferentem” plays a crucial role in the interpretation of contracts in
India, as highlighted by various court decisions. This rule is invoked when
contract terms are genuinely ambiguous, aiming to resolve such ambiguity rather
than creating doubt. Indian courts have consistently applied this principle,
especially in the realm of insurance contracts, which are deemed special
standard contracts demanding utmost good faith from the insured. In instances
where ambiguity arises, the maxim is utilized against the party introducing the
ambiguous term, often favoring the insured. However, the courts emphasize that
contra proferentem is not a tool to create ambiguity but to address existing
uncertainty in contractual language.
The impact of these court decisions
on Indian contract law is significant. They underscore the importance of
clarity in contractual language and discourage parties from exploiting
ambiguities. The application of contra proferentem in insurance contracts,
where fairness and good faith are paramount, reinforces the need for
transparency and unambiguous terms. The rulings emphasize that if a contract is
clear and unambiguous in its overall language, the maxim may not be invoked,
promoting a fair and equitable interpretation of contracts in the Indian legal
landscape.
Furthermore, these court decisions
reflect the evolving nature of contract interpretation in India, where the
courts acknowledge the need to balance contractual autonomy with fairness and
protection of the weaker party. The principle of contra proferentem acts as a
safeguard against potential abuses and ensures that contracts are construed in
a manner consistent with the reasonable expectations of the parties involved.
While the Indian Contract Act of 1872 may lack detailed provisions on contract
drafting and interpretation, judicial application of principles like contra
proferentem serves as a dynamic and responsive approach, adapting to the
complexities of modern contractual relationships. This pragmatic stance by the
Indian courts contributes to legal certainty and reinforces the idea that
contractual obligations should be transparent, equitable, and aligned with the
principles of justice and good faith.
CONCLUSION
In essence, the journey through the
historical evolution and application of the "contra proferentem"
rule in contract law provides a comprehensive understanding of its
significance. Stemming from a need for clarity and fairness in contractual
relationships, this principle has traversed through legal landscapes, adapting
to the changing dynamics of contract interpretation. Delving into its
historical development, we witness its emergence as a safeguard against
ambiguity and exploitation, evolving into a rule invoked when terms are
genuinely unclear.
As we explore its applications,
particularly in the nuanced realm of insurance contracts, the principle emerges
as a guardian of fairness, demanding utmost good faith and transparency from
the parties involved. The impact on Indian contract law is substantial, as
these court decisions highlight the delicate balance between contractual
autonomy and the protection of the weaker party. The pragmatic application of "contra
proferentem" in Indian courts acts as a responsive approach, filling
the gaps left by statutory provisions and ensuring that contracts align with
principles of justice and good faith.
The "contra proferentem"
principle, with its roots in historical legal thought, continues to play a
pivotal role in shaping the interpretation of contracts in India. It stands as
a testament to the legal system's adaptability, addressing complexities in
modern contractual relationships and reinforcing the core values of fairness,
transparency, and justice.
[1] Dr. O.N. Ravi, The Contractual
Interpretation Rule- Contra Proferentem: It’s Relevance in Modern Law, 2,
CMR Uni. J. Cont. Leg. Aff., 112, 113 (2022).
[2] Section 10, The Indian Contract
Act, 1872.
[3] Aparaijita Haripriya Mannava, The
Legal Validity of Self-Prescribed Rules of Interpretation and Construction of
Contracts, 5 Int. J. Law Man. & Hum., 859, 859-860 (2022).
[4] Id. at 859.
[5] Vincet R. Martorana & Michael
K. Zitelli, A Guide to Contract Interpretation, Reed Smith LLP, 1, 5
(2013).
[6] HEIN KOTZ, Contract Law TRANSLATED
BY GILL MERTENS & TONY WEIR, CH.6 (Oxford, 2017).
[7] Id at 05.
[8] Peter Cserne, Policy
Considerations in Contract Interpretation: The Contra Proferentem Rule from A
Comparative Law and Economics Perspective, 5 Uni. Hull, 1, 114 (2007).
[9] O.N. Ravi, supra note 1, at
115.
[10] David Horton, Flipping the Script:
Contra Proferentem and Standard Form Contracts, 80, Uni. Col. Law Rev., 432,
473 (2009).
[11] SIR KIM LEWISON, The
Interpretation of Contracts, 360 (South Asian Reprint 2016).
[12] Chapter 4, UNIDROIT Principles,
2016.
[13] See Article 1157 & 1158 of The
French Code Civil, 1804; Article 1284 & 1286 of The Spanish Codigo Civil,
2016; Article 1367-1369 of The Italian Codice Civil, 1942; Article 4.4 &
4.5 of The UNIDROIT Principles.
[14] Peter, supra note 8, at 8.
[15] Characteristically, the rule was
included in all the European codifications until the end of the 19th
century, but not in general contract law rules. These countries have codified
the contra proferentem rule for standard form of contracts only. Later, mainly
in accord with the European directive, every non-negotiated consumer contracts
became subject to the rule too.
[16] Peter, supra note 8, at
7-8.
[17] Article 1162, The French Civil
Code, 1804.
[18] Peter, supra note 8, at 8.
[19] Dr. REINHARD ZIMMERMANN, The Law
of Obligations, Roman Foundations of the Civilian Tradition, 639-640 (Juta
& Co. Ltd, 1992).
[20] O.N. Ravi, supra note 1, at
116.
[21] O.N. Ravi, supra note 1, at
117.
[22] Jonna McCunn, The Contra
Proferentem Rule: Contract Law’s Great Survivor, 39(3), Oxf. J. Leg. Stud.,
483, 505 (2019).
[23] Hein, supra note 6, at CH.6.
[24] Sir Kim, supra note 10, at
362.
[25] Justice Binnie, Co-operators Life
Insurance Co. v. Gibbens, (2009) 3 SCR 605.
[26] Houghton v. Trafalgar Insurance
Co. Ltd., (1954) 1 QB 247.
[27] Terson Ltd. v. Stevenage
Development Corporation, (1963) EWCA Civ J1023-3.
[28] Johnson v. Edgware & Railway
Co., 55 E.R. 982.
[29] Savil Brothers Ltd. v. Bethell,
(1902) 2 Ch 253.
[30] Burton v. English,
ECLI:EU:C:1982:58.
[31] CDV Software Entertainment AG v.
Gamecock Media Europe Ltd., (2009) EWHC 2965 (Ch).
[32] Cornish v. Accident Insurance Co.,
Civil Action No. 3:06CV-344-DW.
[33] O.N. Ravi, supra note 1, at
123.
[34] J.W CARTER, Carter’s Breach of
Contract, 48 (Hart Publishing, 2018).
[35] MP Ram Mohan & Anmol Jain, Exclusion
Clauses Under the Indian Contract Law: A Need to Account for Unreasonableness,13
NUJS L. Rev., 1, 2 (2020).
[36] EDWIN PEEL, Treital on the Law of
Contract, 7-15 (Sweet & Maxwell,2020).
[37] Jonna, supra note 21, at
492.
[38] Aparajita, supra note 3, at 860.
[39] Section 91 through Section 97,
Indian Evidence Act, 1872.
[40] Abhishek Akshantaka, Analyzing
the Jurisdictional Arbitrage Potency of Indian Contract Law: With the Distinct
Application of the Parol Evidence Rule of Contract Interpretation, 8, Asian
Law Public Policy Rev., 137, 142-143 (2023).
[41] O.N. Ravi, supra note 1, at
129.
[42] Halbury’s Laws of England (5th
ed, 2016) 60, para 105.
[43] United India Insurance Co. Ltd. v.
M/S. Orient Treasures Pvt. Ltd., 2016 (3) SCC 49.
[44] M/S. I.P. & Investment Corpn.
V. New India Assuance Co. Ltd., Civil Appeal No. 1130 of 2007.
[45] Rashtriya Ispat Nigam Ltd. v.
Dewan Chand Ram Saran, AIR 2012 SC 2829.
[46] General Assurance Society Ltd. v.
Chandmull Jain and Anr., 1966 SCR (3) 500.
[47] United India Insurance Co. Ltd. v.
M/S. Pushpalaya Printers, AIR 2004 SC 1700.
[49] Bank of India v. K. Mohandas,
& Ors., Civil Appeal No. 1942 of 2009.
[50] Sushilben Indravadan Gandhi v. The
New Indian Assurance Company, (2021) 7 SCC 151.
Article Information
CONTRA PROFERENTEM: AN IN-DEPTH ANALYSIS OF IT’S HISTORICAL EVOLUTION, PRINCIPLES, AND IMPACT ON INDIAN CONTRACT LAW
Authors: GULNAR ARORA
- Journal IJLRA
- ISSN 2582-6433
- Published 2024/02/22
- Issue 7
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International Journal for Legal Research and Analysis
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