Facts of the Case
‘A’ intentionally and falsely represents to ‘B’ that a particular piece of land belongs to him. Relying on this false representation, ‘B’ purchases the land and pays the agreed consideration to ‘A’.
Subsequently, the land legally comes into the ownership of ‘A’. After acquiring title, ‘A’ approaches the court seeking to set aside the sale, contending that at the time of the sale, he had no title, and therefore the transaction is invalid.
Issues in the Case
- Whether ‘A’ is estopped from denying his earlier representation of ownership?
- Whether ‘A’ can avoid the sale on the ground that he had no title at the time of sale?
- Whether the doctrine of estoppel under the Indian Evidence Act, 1872 applies to the present facts?
Legal Principles Covered to Support Case Proceedings and Judgements
A. Doctrine of Estoppel – Section 115, Indian Evidence Act, 1872
Section 115 states:
When one person has, by his declaration, act or omission, intentionally caused or permitted another person to believe a thing to be true and to act upon such belief, neither he nor his representative shall be allowed, in any suit or proceeding, to deny the truth of that thing.
Essential elements of estoppel:
- A false representation or conduct by A
- Intention or knowledge that it would be acted upon
- Reliance by B
- Alteration of position by B acting upon that belief
All these elements are clearly satisfied in this case.
B. Estoppel by Representation of Ownership
- A falsely held himself out as the owner of the land.
- B acted upon this representation in good faith.
- The law prevents A from later denying the truth of what he earlier asserted.
This is a classic case of estoppel by conduct.
C. Effect of Subsequent Acquisition of Title
- Once A later acquires title, estoppel operates against him.
- The benefit of the subsequently acquired title passes to B.
- A cannot be permitted to take advantage of his own fraud.
D. Supporting Judicial Principles
- Pickard v. Sears
- A person who induces another to act on a belief cannot later deny that belief.
- B.L. Sreedhar v. K.M. Munireddy (2003)
- The Supreme Court recognized estoppel by conduct and acquiescence as binding.
- Motilal Padampat Sugar Mills v. State of U.P.
- A party is prevented from going back on a representation when another has relied on it.
E. Application to the Present Facts
- A knowingly misrepresented ownership.
- B paid consideration and altered his legal position.
- Allowing A to avoid the sale would lead to manifest injustice.
Possible Judgement
The Court is likely to hold that:
- ‘A’ is estopped under Section 115 of the Indian Evidence Act, 1872 from denying his earlier representation.
- ‘A’ cannot set aside the sale on the ground that he had no title at the time of sale.
- The subsequent acquisition of title by ‘A’ enures to the benefit of ‘B’.
- The suit filed by ‘A’ is liable to be dismissed.
Final Conclusion
‘A’ cannot succeed in setting aside the sale. By intentionally making a false representation and inducing ‘B’ to act upon it, ‘A’ is estopped under Section 115 of the Indian Evidence Act, 1872 from denying his title. The law does not permit a person to benefit from his own misrepresentation or fraud.
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