A intentionally and falsely leads B to believe that land belongs to A, and thereby induces B to buy and pay for it. The land afterwards becomes the property of A, and A seeks to set aside the sale on the ground that, at the time of the sale, he had no title. Decide.

Facts of the Case

‘A’ intentionally and falsely represented to ‘B’ that a certain piece of land belonged to him. Relying on this misrepresentation, B purchased the land from A and paid the agreed consideration.

At the time of the sale, A did not have legal title to the land. Subsequently, the land legally became the property of A.

After acquiring title, A seeks to set aside the sale, claiming that the transaction was invalid because he had no title at the time of sale. The question arises whether A can legally rescind the sale despite having misled B.

Issues in the Case

1. Whether ‘A’ can deny the truth of his previous representation regarding ownership of the land?
2. Whether B can rely on A’s false representation even though title was absent at the time of sale?
3. Whether the doctrine of estoppel under Section 115 of the Indian Evidence Act, 1872 prevents A from setting aside the sale?

Legal Principles Covered to Support Case Proceedings and Judgments

A. Doctrine of Estoppel – Section 115, Indian Evidence Act, 1872

Section 115 provides that:

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 to deny the truth of that thing.

Essentials of estoppel:

1. A representation by words, act, or omission.
2. Intention that the other party relies on it.
3. Reliance by the other party.
4. Change of position by acting on that belief.

In this case, all these elements are clearly present.

B. Estoppel Against Denying Title

• A cannot benefit from his own fraud.
• By inducing B to purchase land on false representation, A is estopped from denying ownership, even if he later acquires title.
• Estoppel prevents contradicting prior statements or acts that caused another to act to their detriment.

C. Equity and Prevention of Fraud

• The doctrine ensures protection against fraudulent inducement.
• Allowing A to rescind the sale would amount to unjust enrichment at B’s expense.
• Estoppel promotes fair dealing and reliance on representations.

D. Judicial Precedents

1. Ram Mohan v. Rajan – Held that a person cannot set aside a sale induced by fraudulent misrepresentation.
2. Courts have consistently ruled that estoppel bars a seller from denying title when he misled the buyer, even if title subsequently vests in him.

Possible Judgment

The Court is likely to hold that:

1. ‘A’ intentionally misrepresented ownership of the land and induced B to act upon it.
2. Under Section 115 of the Indian Evidence Act, 1872, ‘A’ is estopped from denying the truth of his earlier representation.
3. The subsequent acquisition of title by ‘A’ does not entitle him to set aside the sale.
4. The sale in favour of B is valid and enforceable, and A cannot rescind it to the detriment of B.

Final Decision

‘A’ cannot avoid or rescind the sale. By virtue of estoppel under Section 115 of the Indian Evidence Act, 1872, the sale in favour of B remains valid, and A is barred from denying his prior misrepresentation regarding ownership.

About lawgnan

If you want to understand complex legal doctrines like estoppel, misrepresentation, admissibility of evidence, or property disputes, Lawgana.in is your trusted partner. Explore expert-crafted legal notes, case laws, practical examples, and simplified explanations designed specifically for law students, judiciary aspirants, and legal professionals. Stay updated on crucial topics under the Indian Evidence Act, IPC, CrPC, Contract Act, and more. Visit Lawgana.in today to build a strong legal foundation, improve exam preparation, and gain clarity on important legal principles. Join thousands of learners who rely on Lawgana.in for accurate, reliable, and high-quality legal content.