Section 61 of the Transfer of Property Act, 1882 (TPA) deals with a borrower who has given two or more mortgages to the same lender. Unless they have agreed otherwise, once the principal money of two or more of those mortgages has become due, the borrower (the mortgagor) may redeem any one of them on its own, or any two or more of them together.
Its mirror image on the lender’s side is Section 67A: a mortgagee who sues on one of several mortgages from the same mortgagor for foreclosure or sale must, absent a contract to the contrary, sue on all of them that are due.
Section 61 TPA at a glance
- Who: a mortgagor who has executed two or more mortgages in favour of the same mortgagee (Section 61).
- When: when the principal money of any two or more of those mortgages has become due (Section 61).
- What: he may redeem any one such mortgage separately, or any two or more of them together (Section 61).
- Exception: a “contract to the contrary” between the parties displaces this rule (Section 61).
- Lender’s side: a mortgagee suing on one of several mortgages for the same kind of decree must sue on all those that are due, unless the contract says otherwise (Section 67A).
- Time limit: a mortgagor’s suit to redeem must be filed within thirty years from when the right to redeem accrues (Article 61(a), Limitation Act, 1963).
Reviewed and updated by Century Law Firm, Delhi – October 2026. Statutory references are to the Acts as in force on that date. The Transfer of Property Act, 1882 is quoted from its English text on India Code (which carries no “as on” date; its latest amendment note is of 2019) and from its official Hindi text on India Code, the Limitation Act, 1963 from India Code (as on 30 August 2026), the Code of Civil Procedure, 1908 from India Code (as on 10 January 2026), and the judgments from the Supreme Court’s official copies.
Section 61 of the Transfer of Property Act: the text
Section 61 sits in Chapter IV of the Act (“Of Mortgages of Immoveable Property and Charges”), under the sub-heading “Rights and Liabilities of Mortgagor”. It reads:
“61. Right to redeem separately or simultaneously.—A mortgagor who has executed two or more mortgages in favour of the same mortgagee shall, in the absence of a contract to the contrary, when the principal money of any two or more of the mortgages has become due, be entitled to redeem any one such mortgage separately, or any two or more of such mortgages together.”
The India Code text notes that the section was “Subs. by s. 24” of the Transfer of Property (Amendment) Act, 1929 (Act 20 of 1929) “for s. 61”; no later amendment is shown. The same 1929 Act also inserted Sections 60A, 60B and 67A and substituted Section 91.
In the official Hindi text, संपत्ति-अंतरण अधिनियम, 1882 (1882 का अधिनियम संख्यांक 4), published on India Code, Section 61 reads:
“61. पृथक्तया या साथ-साथ मोचन कराने का अधिकार—वह बंधककर्ता, जिसने दो या अधिक बंधक एक ही बंधकदार के पक्ष मे निष्पादित कर दिए हैं, तत्प्रतिकूल संविदा न हो तो उस समय, जब उन बंधकों में से दो या अधिक बंधकों का मूलधन शोध्य हो गया हो, ऐसे किसी एक बंधक का पृथक्त: या ऐसे बंधकों में से एक साथ ही दो या अधिक बंधकों का मोचन कराने का हकदार होगा ।”
Does Section 61 apply in Delhi? Section 1 of the Act says it “extends in the first instance to the whole of India” except certain territories, including Delhi, and may be extended to them by notification. India Code’s note to Section 1 records that Sections 54, 107 and 123 were extended to Delhi from 30 May 1939 and that “the remaining provisions were also extended to the Union territory of Delhi w.e.f. 1-12-1962”; India Code also lists the Act among the laws of Delhi, with Section 61 in the same words.
What Section 61 means in plain words
Section 61 has four parts.
- The same parties. One mortgagor “has executed two or more mortgages in favour of the same mortgagee”.
- Principal money due. The choice arises “when the principal money of any two or more of the mortgages has become due”, the same starting point as the right to redeem in Section 60.
- No contract to the contrary. If the mortgage-deeds or another agreement provide otherwise, that contract governs.
- The choice itself. The mortgagor may “redeem any one such mortgage separately, or any two or more of such mortgages together”.
Section 61 is about separate mortgages; it does not allow a single mortgage to be split. Under Section 60, a person “interested in a share only of the mortgaged property” cannot redeem his own share alone on paying a proportionate part of the amount due, except where the mortgagee (or all the mortgagees) “has or have acquired, in whole or in part, the share of a mortgager”. It is a separate paragraph of Section 60 headed “Redemption of portion of mortgaged property”, not its proviso. Under Section 59A, “mortgagors” and “mortgagees” in this Chapter include “persons deriving title from them”, unless otherwise expressly provided.
A worked example (hypothetical)
This is a hypothetical built only from the words of Section 61, not a reported case. A mortgagor has executed three mortgages, A, B and C, all in favour of the same mortgagee, and nothing says they must be redeemed together.
- The principal money of A and B has become due; that of C has not. The mortgagor may redeem A alone, B alone, or A and B together, and the mortgagee cannot refuse to release A because B is unpaid.
- C is not yet redeemable as of right. In Seth Ganga Dhar v. Shankar Lal (1958) the Supreme Court said that “the right to redeem does not arise till the principal money becomes due”.
- Had the deeds said that none could be redeemed without the others, that would be a “contract to the contrary”, and Section 61 would not apply.
Prepared by Century Law Firm from Sections 60, 61 and 67A of the Transfer of Property Act, 1882 (India Code) and Article 61 of the Schedule to the Limitation Act, 1963 (India Code, as on 30 August 2026).
The right to redeem under Section 60
In Section 60, “At any time after the principal money has become due, the mortgagor has a right, on payment or tender, at a proper time and place, of the mortgage-money, to require the mortgagee” (a) to deliver to him “the mortgage-deed and all documents relating to the mortgaged property which are in the possession or power of the mortgagee”, (b) where the mortgagee is in possession, to deliver possession, and (c) at the mortgagor’s cost, to re-transfer the property to him or to a third person he directs, or to execute (and, for a registered mortgage, have registered) a written acknowledgement that “any right in derogation of his interest transferred to the mortgagee has been extinguished”.
The proviso reads: “Provided that the right conferred by this section has not been extinguished by act of the parties or by decree of a Court.” The section adds: “The right conferred by this section is called a right to redeem and a suit to enforce it is called a suit for redemption.” A term entitling the mortgagee to “reasonable notice before payment or tender” remains valid.
“Once a mortgage, always a mortgage”
In Shankar Sakharam Kenjale v. Narayan Krishna Gade (17 April 2020) the Supreme Court said: “It is well-settled that the right of redemption under a mortgage deed can come to an end or be extinguished only by a process known to law, i.e., either by way of a contract between the parties to such effect, by a merger, or by a statutory provision that debars the mortgagor from redeeming the mortgage.” A mortgagee in possession must give it up when a redemption suit is filed unless he shows that the right has ended, a rule that “emanates from the legal principle applicable to all mortgages – ‘Once a mortgage, always a mortgage'”.
In Seth Ganga Dhar v. Shankar Lal (15 April 1958) the Court said: “The rule against clogs on the equity of redemption is that, a mortgage shall always be redeemable and a mortgagor’s right to redeem shall neither be taken away nor be limited by any contract between the parties.” A clause making the mortgage-deed a sale deed if the mortgagor did not redeem within six months after the term “cannot be sustained”, the Court held: it “plainly takes away altogether, the mortgagor’s right to redeem the mortgage after the specified period. This is not permissible, for ‘once a mortgage always a mortgage’ and therefore always redeemable.” But the same mortgage’s eighty-five-year term was upheld. That term, the Court said, “does not, of course, take away the mortgagor’s right to redeem and is not, therefore, in that sense, a clog on the equity of redemption”; on the facts, “the bargain was a reasonable one and the eighty-five years term of the mortgage should be enforced”. Relief depends on whether a term was obtained “by taking advantage of any difficulty or embarrassment” of the borrower.
When the right to redeem is lost
In Allokam Peddabbayya v. Allahabad Bank (19 June 2017) the Supreme Court said that “The right to redeem can stand extinguished either by the act of the parties or by operation of the law in the form of a Decree of the Court under the proviso to Section 60 of the Act.” The land had been auctioned in the bank’s mortgage suit and a sale certificate issued before the purchasers of the equity of redemption sued; the Court held that the right, once extinguished, could not be enforced merely because the thirty-year limitation had not expired, as “The right to redemption could not be claimed in the abstract.”
Section 61 and Section 67A: the two sides of several mortgages
Section 67A applies the same idea from the mortgagee’s side. It reads: “67A. Mortgagee when bound to bring one suit on several mortgages.—A mortgagee who holds two or more mortgages executed by the same mortgagor in respect of each of which he has a right to obtain the same kind of decree under section 67, and who sues to obtain such decree on any one of the mortgages, shall, in the absence of a contract to the contrary, be bound to sue on all the mortgages in respect of which the mortgage-money has become due.” Section 67 is the mortgagee’s right to a decree for foreclosure (debarring the mortgagor of his right to redeem) or for sale of the property.
| Point | Section 61 (mortgagor) | Section 67A (mortgagee) |
|---|---|---|
| Who acts | Mortgagor who has executed two or more mortgages in favour of the same mortgagee | Mortgagee who holds two or more mortgages executed by the same mortgagor |
| Trigger | Principal money of any two or more mortgages has become due | He sues on one mortgage for a decree under Section 67, and has a right to the same kind of decree on each |
| Effect | A choice: redeem any one separately, or any two or more together | A duty: sue on all the mortgages on which the mortgage-money has become due |
| Exception | A contract to the contrary | A contract to the contrary |
Section 61 speaks of the “principal money” having become due; Section 67A speaks of the “mortgage-money”, which under Section 58(a) means principal and interest.
Sections 60A to 67: the neighbouring rights
| Section | What it provides |
|---|---|
| 60A | A mortgagor entitled to redemption may require the mortgagee to assign the debt and transfer the property to a third person instead of re-transferring it (not where the mortgagee is or has been in possession). |
| 60B | While the right of redemption subsists, the mortgagor may inspect and copy the title documents held by the mortgagee, at his own cost. |
| 62 | A usufructuary mortgagor may recover possession and the documents when the mortgage-money is paid out of rents and profits, or on paying, tendering or depositing the balance after the term. |
| 63, 63A, 64 | On redemption the mortgagor gets accessions, improvements and the benefit of a renewed lease, paying only in the cases these sections set out. |
| 67 | Mortgagee’s right, after the mortgage-money has become due, to a decree for foreclosure or sale. |
Section 83 lets the mortgagor deposit “the amount remaining due on the mortgage” in court before a redemption suit is barred; interest then stops as Section 84 provides. A mortgage for one hundred rupees or more, other than by deposit of title-deeds, “can be effected only by a registered instrument signed by the mortgagor and attested by at least two witnesses” (Section 59); see the firm’s note on Section 49 of the Registration Act.
Who may sue for redemption: Section 91
Section 91 says: “Besides the mortgagor, any of the following persons may redeem, or institute a suit for redemption of, the mortgaged property, namely:— (a) any person (other than the mortgagee of the interest sought to be redeemed) who has any interest in, or charge upon, the property mortgaged or in or upon the right to redeem the same; (b) any surety for the payment of the mortgage-debt or any part thereof; or (c) any creditor of the mortgagor who has in a suit for the administration of his estate obtained a decree for sale of the mortgaged property.”
In Allokam Peddabbayya the Court said that purchasers of the equity of redemption “can have or claim no better rights under Section 91, than what their predecessor-in-interest had under Section 60 of the Act.” Under Section 92, such a person (other than the mortgagor) or a co-mortgagor who redeems is “subrogated” to the rights of the mortgagee whose mortgage he redeems.
Time limit for a redemption suit: Article 61 of the Limitation Act
The Limitation Act, 1963 sets the time limits for mortgage suits in Part V of its Schedule (“Suits relating to immovable property”). A mortgagor’s suit “to redeem or recover possession of immovable property mortgaged” must be filed within thirty years “When the right to redeem or to recover possession accrues” (Article 61(a)). The firm’s limitation calculator works out the last date.
| Article | Suit | Period | Time begins to run |
|---|---|---|---|
| 61(a) | By a mortgagor, to redeem or recover possession of immovable property mortgaged | Thirty years | When the right to redeem or to recover possession accrues |
| 61(b) | By a mortgagor, to recover possession of mortgaged property afterwards transferred by the mortgagee for valuable consideration | Twelve years | When the transfer becomes known to the plaintiff |
| 62 | To enforce payment of money secured by a mortgage or otherwise charged upon immovable property | Twelve years | When the money sued for becomes due |
| 63(a) | By a mortgagee, for foreclosure | Thirty years | When the money secured by the mortgage becomes due |
How a redemption suit works: Order XXXIV CPC
Mortgage suits are governed by Order XXXIV of the Code of Civil Procedure, 1908 (the old Sections 85 to 90 of the TPA were repealed and re-enacted there). Under Rule 1, “all persons having an interest either in the mortgage-security or in the right of redemption shall be joined as parties”; “a prior mortgagee need not be joined in a suit to redeem a subsequent mortgage.”
If the redemption suit succeeds, the court passes a preliminary decree (Rule 7) taking an account of, or declaring, what is due to the mortgagee and fixing a date for payment within six months, which it may extend “on good cause shown”. If the mortgagor pays, a final decree orders return of the documents, re-transfer and, if necessary, possession (Rule 8(1)); if he does not, the mortgagee may apply for a final decree debarring redemption (for a mortgage by conditional sale or an anomalous mortgage providing only for foreclosure) or for sale (for other mortgages, except a usufructuary mortgage) (Rules 7 and 8). Payment is still possible “before the confirmation of a sale” (Rule 8). In Allokam Peddabbayya the Court read Rule 8 to mean that “the right to redemption survived only till confirmation of the sale and not thereafter.” The firm’s court fee and jurisdiction calculator helps with the court fee and court for a civil suit in Delhi.
Bank loans and SARFAESI: a shorter window
Where a bank enforces a mortgage under the SARFAESI Act, 2002 without going to court, Section 13(8) of that Act (substituted by Act 44 of 2016 from 1 September 2016) protects the borrower only if the dues, costs, charges and expenses are tendered “at any time before the date of publication of notice for public auction or inviting quotations or tender from public or private treaty” for the sale or lease of the secured assets.
In Celir LLP v. Bafna Motors (Mumbai) Pvt. Ltd. (21 September 2023) the Supreme Court held that under the amended Section 13(8) “the right of the borrower to redeem the secured asset stands extinguished thereunder on the very date of publication of the notice for public auction under Rule 9(1) of the Rules of 2002”. See also the firm’s guide to the Debt Recovery Tribunal.
“Section 61” in other laws (dhara 61 kya hai)
Many searches for “dhara 61” are about a different law. This is what Section or Article 61 means in other common Indian laws.
| Law | Section / Article 61 |
|---|---|
| Transfer of Property Act, 1882 | Right to redeem separately or simultaneously (this page) |
| Bharatiya Nyaya Sanhita, 2023 | Section 61: criminal conspiracy (formerly Sections 120A and 120B IPC); official Hindi heading “आपराधिक षड्यंत्र” |
| Indian Penal Code, 1860 | Section 61 (“Sentence of forfeiture of property”) was repealed in 1921 by Act 16 of 1921 |
| Code of Criminal Procedure, 1973 | Section 61: form of summons, now Section 63 of the Bharatiya Nagarik Suraksha Sanhita, 2023 |
| Constitution of India | Article 61: procedure for impeachment of the President |
| Limitation Act, 1963 (Schedule) | Article 61: suits by a mortgagor, including the thirty-year period to redeem |
For the criminal conspiracy provision, see the firm’s note on Section 120B IPC and Section 61 BNS.
संपत्ति-अंतरण अधिनियम की धारा 61 – हिंदी में सारांश (Summary in Hindi)
संपत्ति-अंतरण अधिनियम, 1882 (1882 का अधिनियम संख्यांक 4) की धारा 61 का शीर्षक आधिकारिक हिंदी पाठ में “पृथक्तया या साथ-साथ मोचन कराने का अधिकार” है। इसका अर्थ यह है कि जिस बंधककर्ता (mortgagor) ने दो या अधिक बंधक एक ही बंधकदार (mortgagee) के पक्ष में निष्पादित किए हैं, वह – यदि तत्प्रतिकूल संविदा (contract to the contrary) न हो – उस समय, जब उनमें से दो या अधिक बंधकों का मूलधन शोध्य हो गया हो, किसी एक बंधक का अलग से, या दो या अधिक बंधकों का एक साथ मोचन (redemption) करा सकता है। यह धारा 1929 के अधिनियम सं० 20 की धारा 24 द्वारा प्रतिस्थापित की गई थी।
धारा 60 (“मोचन करने का बंधककर्ता का अधिकार”) के अनुसार मूलधन के शोध्य हो जाने के पश्चात् किसी भी समय बंधककर्ता बंधक धन देकर या निविदत्त करके बंधकदार से बंधक विलेख और सब दस्तावेज़ वापस लेने, कब्ज़ा (यदि बंधकदार के पास है) वापस लेने और संपत्ति के प्रति-अंतरण की अपेक्षा कर सकता है। परन्तुक के अनुसार यह अधिकार तभी तक है जब तक वह पक्षकारों के कार्य द्वारा या न्यायालय की डिक्री द्वारा निर्वापित न हो चुका हो। धारा 60 के शब्दों में, “इस धारा द्वारा प्रदत्त अधिकार मोचन अधिकार कहलाता है और उसे प्रवर्तित कराने का वाद मोचन वाद कहलाता है।” धारा 61 एक बंधक को टुकड़ों में छुड़ाने की अनुमति नहीं देती; धारा 60 के अंतिम पैरा (“बंधक-सम्पत्ति के भाग का मोचन”) के अनुसार बंधक-सम्पत्ति के केवल एक अंश में हितबद्ध व्यक्ति आनुपातिक रकम देकर केवल अपना अंश नहीं छुड़ा सकता (कुछ अपवादों को छोड़कर)।
बंधकदार की ओर से इसका उल्टा नियम धारा 67क में है (“बंधकदार कई बन्धकों के आधार पर एक वाद लाने को कब आबद्ध होता है”)। जो बंधकदार एक ही बंधककर्ता के दो या अधिक बंधक रखता है और उनमें से किसी एक पर धारा 67 के अधीन पुरोबन्ध (foreclosure) या विक्रय की वही किस्म की डिक्री के लिए वाद लाता है, उसे – तत्प्रतिकूल संविदा न हो तो – उन सब बंधकों पर वाद लाना होगा जिनका बंधक धन शोध्य हो गया है। धारा 91 के अनुसार बंधककर्ता के अतिरिक्त कुछ अन्य व्यक्ति भी, जैसे बंधक-सम्पत्ति में हित रखने वाला व्यक्ति या बंधक ऋण का प्रतिभू (surety), मोचन का वाद ला सकते हैं।
परिसीमा अधिनियम, 1963 की अनुसूची के अनुच्छेद 61(क) के अनुसार बंधककर्ता को मोचन का वाद उस तारीख से तीस वर्ष के भीतर लाना होता है जब मोचन का अधिकार प्रोद्भूत होता है (यह फर्म का सारांश है; परिसीमा अधिनियम का आधिकारिक हिंदी पाठ इस लेख के लिए नहीं पढ़ा गया)। सुप्रीम कोर्ट ने शंकर सखाराम केंजले (2020) में कहा कि मोचन का अधिकार केवल विधि द्वारा मान्य तरीके से ही समाप्त होता है – पक्षकारों की संविदा, विलय (merger) या किसी कानूनी प्रावधान से – और यह “Once a mortgage, always a mortgage” के सिद्धांत से निकलता है। ध्यान दें कि भारतीय न्याय संहिता, 2023 की धारा 61 एक अलग प्रावधान (आपराधिक षड्यंत्र) है।
Frequently asked questions
Section 61 of the Transfer of Property Act, 1882, “Right to redeem separately or simultaneously”, lets a mortgagor who has executed two or more mortgages in favour of the same mortgagee, once the principal money of any two or more has become due, redeem any one separately or any two or more together, unless there is a contract to the contrary.
Yes. Under Section 61 of the Transfer of Property Act, a mortgagor who has given two or more mortgages to the same mortgagee may, once the principal money of two or more of them has become due, redeem any one of them separately, unless the parties have agreed otherwise.
Section 61 is a default rule. If the mortgage-deeds or another agreement provide, for example, that the mortgages can only be redeemed together, that contract governs. Section 67A is subject to the same words.
Section 61 gives the mortgagor a choice: when two or more mortgages to the same mortgagee are due, he may redeem one separately or several together. Section 67A puts a duty on the mortgagee: if he sues on one of them for the same kind of decree (foreclosure or sale) under Section 67, he must sue on all on which the mortgage-money has become due, unless a contract provides otherwise.
It is the mortgagor’s right, after the principal money has become due, on paying or tendering the mortgage-money, to require the mortgagee to return the mortgage-deed and documents, give back possession if he holds it, and re-transfer the property. Section 60 calls this the “right to redeem” and a suit to enforce it a “suit for redemption”. Section 60’s proviso keeps it alive unless it has been extinguished by act of the parties or by decree of a court; the Supreme Court has also listed merger and statutory provisions (Shankar Sakharam Kenjale, 2020), and under SARFAESI Section 13(8) it ends on publication of the auction notice (Celir LLP, 2023).
Thirty years from when the right to redeem or to recover possession accrues, under Article 61(a) of the Schedule to the Limitation Act, 1963. The thirty years do not help if the right to redeem has already been extinguished, for example by a court decree and confirmed sale (Allokam Peddabbayya v. Allahabad Bank, 2017).
A term in a mortgage that takes away or unfairly restricts the mortgagor’s right to redeem. In Seth Ganga Dhar v. Shankar Lal (1958) the Supreme Court said that “a mortgage shall always be redeemable” and held invalid a clause turning the mortgage-deed into a sale deed if the mortgagor did not redeem within six months after the term. In the same case an 85-year term was upheld: it did not take away the right to redeem, and on the facts “the bargain was a reasonable one”. Relief depends on whether a term was imposed by taking advantage of the borrower’s difficulty.
The mortgagor and, under Section 91 of the Transfer of Property Act, any person (other than the mortgagee of the interest to be redeemed) with an interest in or charge on the property or the right to redeem it, any surety for the mortgage-debt, and a creditor who has obtained a decree for sale of the property in a suit for administration of the mortgagor’s estate. A purchaser of the equity of redemption can claim no better right under Section 91 than the mortgagor had under Section 60 (Allokam Peddabbayya v. Allahabad Bank, 2017).
Generally no. Section 60 of the Transfer of Property Act says a person interested in a share only of the mortgaged property cannot redeem his own share alone on paying a proportionate part of the amount due, except where the mortgagee (or all the mortgagees) has acquired, in whole or in part, the share of a mortgagor. Section 61 concerns separate mortgages, not shares of one mortgage.
In the official Hindi text, संपत्ति-अंतरण अधिनियम, 1882, Section 61 is headed “पृथक्तया या साथ-साथ मोचन कराने का अधिकार”: a बंधककर्ता who has given two or more बंधक to the same बंधकदार may, unless there is a तत्प्रतिकूल संविदा, redeem any one separately or two or more together once their मूलधन has become due. In criminal law, Section 61 of the Bharatiya Nyaya Sanhita, 2023 is a different provision, on criminal conspiracy (आपराधिक षड्यंत्र).
Under Section 13(8) of the SARFAESI Act, 2002, as substituted from 1 September 2016, the borrower is protected only if the dues, costs, charges and expenses are tendered before the date of publication of the notice for public auction or for quotations or tender. In Celir LLP v. Bafna Motors (2023) the Supreme Court held that the right to redeem is extinguished on the date that notice is published under Rule 9(1).
Conclusion
Section 61 of the Transfer of Property Act lets a borrower who has given more than one mortgage to the same lender clear them one at a time or together once two or more are due, unless their contract says otherwise. It works with the general right to redeem in Section 60 (“once a mortgage, always a mortgage”, in the Supreme Court’s words) and with Section 67A, which obliges a lender suing on one of several due mortgages to sue on all of them. The right ends by act of the parties or a court decree, a redemption suit must be filed within thirty years from when the right accrues, and under SARFAESI the right ends on publication of the auction notice.
Sources used for this post: the Transfer of Property Act, 1882 (Act No. 4 of 1882), Section 1 (with India Code’s footnote on extension, including to Delhi), Sections 58 to 67A, 83, 84 and 85 to 92 with footnotes, English text on India Code (a1882-04.pdf; no “as on” date printed; latest amendment note Act 34 of 2019) and official Hindi text on India Code (H1882-04.pdf; Sections 60, 61, 67A and 91 read from the printed pages); the Limitation Act, 1963, Schedule, Articles 61 to 63, India Code (as on 30 August 2026); the Code of Civil Procedure, 1908, Order XXXIV Rules 1 and 7 to 9, India Code (as on 10 January 2026); the SARFAESI Act, 2002, Section 13(8), India Code (a2002-54.pdf; substituted by Act 44 of 2016 w.e.f. 1 September 2016); the Bharatiya Nyaya Sanhita, 2023 (Section 61, English text as on 6 October 2025 and official Hindi text), the Bharatiya Nagarik Suraksha Sanhita, 2023 (Section 63, as on 6 October 2025), the Indian Penal Code, 1860 (Section 61, India Code) and the Constitution of India (Article 61, Legislative Department edition as on 10 September 2026), and the firm’s Gazette-checked section data; Supreme Court of India judgments: Seth Ganga Dhar v. Shankar Lal & Others, 15 April 1958, https://api.sci.gov.in/jonew/judis/528.pdf; Allokam Peddabbayya v. Allahabad Bank, Civil Appeal Nos. 2763-2764 of 2008, 19 June 2017, https://api.sci.gov.in/supremecourt/2006/11795/11795_2006_Judgement_19-Jun-2017.pdf; Shankar Sakharam Kenjale v. Narayan Krishna Gade, Civil Appeal No. 4594 of 2010, 17 April 2020, https://api.sci.gov.in/supremecourt/2009/21191/21191_2009_32_1501_21665_Judgement_17-Apr-2020.pdf; Celir LLP v. Bafna Motors (Mumbai) Pvt. Ltd., Civil Appeal Nos. 5542-5543 of 2023, 21 September 2023, https://api.sci.gov.in/supremecourt/2023/34154/34154_2023_1_1501_47088_Judgement_21-Sep-2023.pdf.
