Nirma University Institue of Law Final Draft of the Project Work “Effect of Material Alternation in Negotiable Instrument”
undertaken in the partial fulfillment of B.Com. LL.B. (Hons.) 5 !ears "nte#rated Course at "nstitute of La$% &"' *ni+ersit,. Submitted By:
Mohit Mittal Roll No. 11BBL059 IV - Semester, Section – C Under The Guidance Of:
Mr. Nizam han !ro"ect Coor#inator$ Contract -II %sst. !ro&essor, Instit'te o& La( Nirma )ni*ersit+
Introduction A material alteration, though not defined in the Indian Contract Act or in the Negotiable Instrument Act, 1881 or does receive any definition from legislature, it would be appropriate to refer to udgment or legal precedents for defining the term !material alternation"# In Nathu Lal v# $omti %aur, the privy council cited the following definition &the material alternation is one which varies the rights, liabilities, or legal position of the parties ascertained by the deed in its original state or otherwise varies the legal effect of the instrument as originally e'pressed, or reduces to certainty some provision which was originally unascertained and as such void, or may otherwise preudice the party bound by the deed as originally e'ecuted,( As per section 88 of the Negotiable Instrument Act, 1881 the effect of material alternation of a negotiable instrument renders the contract void as against anyone who is party thereto at the time of ma)ing such alteration and does not consent thereto, unless it was made in order to carry out the common intention of the original parties# *wo other +ections of the Negotiable Instruments Act, 1881 which dea l with material alterations, are as under As per +ection 88, Acceptor or endorsers are bound notwithstanding previous alteration# An acceptor or endorser of a negotiable instrument is bound by his acceptance or endorsement notwithstanding any previous alteration of the instrument#. Again as per the +ection 8/, 0ayment of instrument on which alteration is not apparent# 213 4here a promissory note, bill of e'change or che5ue has been materially altered but does not appear to have been so altered, or where a che5ue is presented for payment which does not at the time of presentation appear to be crossed or to have had a crossing which has been obliterated, payment thereof by a tenor thereof at the time of payment and otherwise in due course, shall discharge such person or ban)er from all liability thereon6 and such payment shall not be 5uestioned by reasons of the instrument having be en altered, or the che5ue crossed# 273 4here the che5ue is an electronic image of and the truncated che5ue shall be a material alteration and it shall be the duty of the ban) or the clearing house, as the case may be, to ensure the e'actness of the apparent tenor of electronic image of the truncated che5ue while truncating and transmitting the image#
23 Any ban) or a clearing house which receives a transmitted electronic image of a truncated che5ue, shall verify from the party who transmitted the image to it, that the image so transmitted to it and received by it, is e'actly the same#
Chapter – I
Introduction Negotiable Instrument Act was enacted, in India, in 1881# 9efore this, the :nglish Negotiable Instrument Act was applicable in India# *hough, the present act is also based on the :nglish Act with Indian modifications# It e'tends to the whole of India e'cept the +tate of ;ammu and %ashmir# It was enacted with the aim &to define and amend the law relating to promissory notes, bills of e'change and che5ue.# It is a document guaranteeing the payment of a specific amount of money, either on demand, or at a set time# Negotiable instrument are often defined in legislation# A negotiable instrument is one, therefore, which when transferred by delivery or by endorsement and delivery, passes to the transferee a good title to payment according to its tenor and irrespective of the title of the transferor, provided he is bonafide holder for value without notice of any defect attaching to the instrument or in the title of the transferor6 in other words the principle nemo dat quod non habit does not apply1# *he negotiable instrument includes a promissory note, bill of e'change and che5ue7#
According to +ection 1 2a3 of the Act, &Negotiable instrument means a promissory note, bill of e'change or che5ue payable either to order or to bearer, whether the word &order. or & bearer. appear on the instrument or not#. In the words of ;ustice 4illis, &A negotiable instrument is one, the property in which is ac5uired by anyone who ta)es it bonafide and for value notwithstanding any defects of the title in the person from whom he too) it# *hus, the term, negotiable instrument means a written document which creates a right in favor of some person and which is freely transferable# Although the Act mentions only these three instruments 2such as a promissory note, a bill of e'change and che5ue3, it does not e'clude the possibility of adding any other instrument which satisfies the following two conditions of negotiability -
*he instrument should be freely transferable 2by delivery or by endorsement# and delivery3 by the custom of the trade6 and
- 9hashyam < Adiga"s, *he Negotiable Instruments Act, 18 th :dition, 9harat Law =ouse New >elhi +ection ?, @ and of Indian Negotiable Instrument Act, 1881
*he person who obtains it in good faith and for value should get it free from all defects, and be entitled to recover the money of the instrument in his own name# CHARACTERITIC !" A NE#!TIA$%E INTR&MENT
*he Negotiable Instruments has the following characteristics -
'ropert( - the possession holder of the negotiable instrument is presumed to be the owner of
the property contained therein# A negotiable instrument can be transferred from one person to another without any comple' formalities#
Title - *he transferee of a negotiable instrument is )nown as !holder in due course#" A bona fide
transferee for value is not affected by any defect of title on the part of the transferor or of any of the previous holders of the instrument# /
Rights - *he holder in due course can sue in his own name, in case of dishonor# A negotiable
instrument can be transferred any number of times till it is at maturity# *he holder of the instrument need not give notice of transfer to the party liable on the instruments to pay# 0
'resumptions - Certain presumptions apply to all negotiable instruments, e#g# the consideration
has been paid under it and it is not necessary to write every time that &for value received.# 5
'rompt 'a(ments - A negot i abl ei ns t r umentenabl es t he hol der t oe xpectpr ompt paymentbec ausea di shonormeans t he r ui n oft hecr edi to fal lper sons who ar e pa r t i e st ot hei ns t r ume nt
T)'E !" NE#!TIA$%E INTR&MENT
+ection 1 of the Negotiable Instruments Act, 1881 states, that a, negotiable instrument means a promissory note, bill of e'change or che5ue payable either to order or to bearer# 9ut these are not the end# *he customary practices recogniBes more than what is laid down in the Act# It also includes =undis, +hare 4arrants, >ividend 4arrants, 9an)ers >raft, Circular Notes, 9earer >ebentrues, >ebentures of 9ombay 0ort *rust, ailway eceipts, >elivery Drders, etc# *hus, as per the :'planation 2i3 to +ection 1, A promissory note, bill of e'change or che5ue is pa yable to order which is e'pressed to be so payable or which is e'pressed to be payable to a particular person, and does not contain words prohibiting transfer or indicating an intention that it shall not be transferable#
:'planation 2ii3 - A promissory note, bill of e'change or che5ue is payable to bearer which is e'pressed to be so payable or on which the only or last endorsement is an endorsement in blan)# :'planation 2iii3 - 4here a promissory note, bill of e'change or che5ue, either originally or by endorsement, is e'pressed to be payable to the order of a specified person, and not to him or his order, it is nevertheless payable to him or his order at his option#E -
'romissor( Note - +ection ? of the Act defines, &A promissory note is an instrument in writing
2note being a ban)-note or a currency note3 containing an unconditional underta)ing, signed by the ma)er, to pay a certain sum of money to or to the order of a certain person, or to the bearer of the instruments#. *hus, if any instruments that satisfy the following conditions can be regarded as the promissory note a
It must be in 4riting
1
It must certainly an e'pressed promise or clear understanding to pay
c
0romise to pay must be unconditional
d
It should be signed by the ma)er
e
2he maker must 1e certain.
f
2he pa,ee must 1e certain
#
2he promise should 1e to pa, mone, and mone, onl,
h
2he amount should 1e certain
i
3ther formalities
$ill of E*change - +ection @ of the Act defines, &A bill of e'change is an instrument in writing
containing an unconditional order, signed by the ma)er, directing a certain person to pay a certain sum of money only to, or to the order of a certain person or to the bearer of the instrument.# A bill of e'change, therefore, is a written ac)nowledgement of the debt, written by the creditor and accepted by the debtor# *here are usually three parties to a bill of e'change drawer, acceptor or drawee and payee# >rawer himself may be the payee+ :ssentials Characteristics of a bill of e'change are as follows a
It must be in writing and should be signed by the drawer#
1
*he drawer, drawee and payee must be certain#
c
*he sum payable must also be certain#
d
It should be properly stamped#
e
It must contain an e'press order to pay money and money alone#
/
Che,ue - +ection of the Act defines &A che5ue is a bill of e'change drawn on a specified
ban)er, and not e'pressed to be payable otherwise than on demand.# A che5ue is bill of e'change with two more 5ualifications, namely, i
it is always drawn on a specified ban)er, and
ii
it is always payable on demand# Conse5uently, all che5ues are bill of e'change, but all bills are not che5ue# A che5ue must satisfy all the re5uirements of a bill of e'change6 that is, it must be signed by the drawer, and must contain an unconditional order on a specified ban)er to pay a certain sum of money to or to the order of a certain person or to the bearer of the che5ue# It does not re5uire acceptance#
Chapter – II -e.elopment of Negotiable Instruments in India Negotiable instruments are those special writings 2&commercial specialties.3 used in commerce as a means of transferring money or the right to it# *he most familiar is the chec), but it is merely a special type of a general instrument, the draft or bill of e'change# *hus, Negotiable instrument, is essentially a document embodying a right to the payment of money and which may be transferred from person to person, developed historically from efforts to ma)e credit instruments transferable6 that is, documents proving that somebody was in their debt were used by creditors to meet their own liabilities# *his &negotiability of credit. was facilitated by the development of a variety of negotiable instruments including promissory notes, chec)s, and drafts 2bills of e'change3# *hese are in fact the most common negotiable instruments in use, and the following discussion will be confined to them#
In India, Negotiable Instruments has a long history much before the act was enacted in the country# In India, there is reason to believe that instrument to e'change were in use from early times and there are evidences and researched papers representing that paper money were introduced in the country by one of the Fohammedan sovereigns of >elhi in the early part of the fourteenth century# *he word GhundiG, a generic term used to denote instruments of e'change in vernacular is derived from the +ans)rit root GhundG meaning Gto collectG and well e'presses the purpose to which instruments were utilised in their origin# 4ith the advent of 9ritish rule in India commercial activities increased to a great e'tent# *he growing demands for money could not be met be mere supply of coins and hard money6 and thus, the instrument of credit too) the function of money which they represented#?
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4ith the 9ritishers, starting to coloniBe more and more parts of India by increasing the commercial activities, the need for the credit transactions arises which cannot be met with the oral terms as before# *hus, a need for the separate instruments for handling credit transaction started ta)ing place and therefore the negotiable instruments finds the way for its origin# *o overcome the applicability all over the country, a separate act was enacted named as Negotiable Instruments Act, 1881
9efore the enactment of the Negotiable Instrument Act, 1881, in India, the law of negotiable instruments as prevalent in :ngland was applied by the Courts in India when any 5uestion relating to such instruments arose between :uropeans# 4hen then parties were =indu or Fohammedans, their personal law was held to apply# *hough neither the law boo)s of =indu nor those of Fohammedans contain any reference to negotiable instruments as such, the customs prevailing among the merchants of the respective community were recogniBed by the courts and applied to the transactions among them# >uring the course of time there had developed in the country a strong body of usage relating to hundis, which even the Legislature could not without hardship to Indian ban)ers and merchants ignore# In fact, the Legislature felt the strength of such local usages and though fit to e'empt them from the operation of the Act with a proviso that such usage may be e'cluded altogether by appropriate words# In the absence of any such customary law, the principles derived from :nglish law were applied to the Indians as rules of e5uity ustice and good conscience#
Chapter / III Material Alteration and its Constituents Faterial alteration is undefined in the Indian Contract Act, 187 or in the Negotiable Instrument Act, 1881 or does receive any definition from legislature, it would be appropriate to refer to udgment or legal precedents for defining the term !material alternation"# In Nathu Lal v# $omti %aur @, the privy council cited the following definition &the material alternation is one which varies the rights, liabilities, or legal position of the parties ascertained by the deed in its original state or otherwise varies the legal effect of the instrument as originally e'pressed, or reduces to certainty some provision which was originally unascertained and as such void, or may otherwise preudice the party bound by the deed as originally e'ecuted,(# *hus, material alteration in the negotiable instrumetns can be defined as &any change in the instruments which causes the instruments to spea) a different language in legal effect from that which it originally spo)e, or which changes the legal identity of the instruments either in terms of the relations of the parties to it or any other relevant changes due to which there is a change in the legal position of the parties without the consent of the other is regarded as a material alteration# It is not necessary that all the changes made in the negotiable instruments with or without the consent of the parties shall be considered as the material alteration on the assumption that it is carried out without the consent of the other party# It is not the case# +ome alterations are material while some are immaterial# It is immaterial whether the alteration is advantageous or disadvantageous# Alteration must be intentional# An accidental alteration is not bad# It need not be made by the holder# It is sufficient if it was made when the instrument was in the possession of the holder# *he holder must ta)e every care to protect it from such alteration6 otherwise he will be liable for the conse5uence of the alteration#
5 AI 1/?J 0C 1J
+ome alteration is material and some are immaterial# An alteration is material if it alters materially or substantially the operation of the instrument and thereby the rights and liabilities of the parties# It can also be said that &An alteration which alters the business effect if the instrument if used for any business purpose# Any change made in the instrument that causes it to spea) a different language from what it originally intended, or which changes the legal identity of the instrument in its terms or in relation to parties thereto is a material alteration#. *hough it differs from fact to fact, but some alterations are considered as the material in all the circumstances irrelevant of the nature of the negotiable instruments# +ome of these can be classified as
1# >ate of instrument is altered 7# +um payable is altered # *ime and place of payment are altered or adding a specific place, where no place of ?# @# # #
payment is specified, ate of interest is altered6 *earing an instrument in material part6 Change of dates of endorsement etc# Fedium or currency in which payment is to be made is altered
*he list is not an e'haustive but only a suggestive and can be varied according to the circumstances of each and every case# *hus, if any alteration affects the very or said purpose of the original instrument, that is, if it goes to the root of the instrument, it is considered to b e a material alteration#
Alterations Authori0ed b( the Act *here are some alterations already provided by the Negotiable Instruments Act, which if made does not amount to material alteration# *hese are 1# "illing an inchoate but stamped instrument 1ec+ 2345 / the holder has the authority to fill in the blan)s in such an instrument# :ven where the holder fills an amount larger than intended 2but is covered by the stamp3 the instrument is not void against a holder in due course#
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7# Con.ersion of an endorsement in blan6 into an endorsement in full 1ec+ 784 - *he holder has the authority to convert an indorsement in blan) into an indorsement in full# # Conditional or 9ualified Acceptance 1ec+ :;45 / A holder has a option to ta)e a 5ualified acceptance ?# Crossing of Che,ues after it has been issued 1ec+ <2=4 - # A holder and ban)er are empowered to cross the che5ues after it has been issued, the alteration being provided by the Act#
Alterations not .itiating the Instrument Again, the following alteration does amount to material alteration in the instruments and does not vitiate the instruments or declared it as void 1# 7# # ?#
Conversion of an instrument !payable to bearer" into an instrument !payable to order# Alteration to rectify mista)es, Addition of the words !on demand" in an instrument, where no time of payment is stated# Alteration made before the issue, delivery or negotiation, that is, with the completion of
the instrument, @# Alterations made at any time with the consent of the parties6 # Alterations resulting from an accident6 # Alteration of any note on the margin of an instrument which is neither a part to it, nor is covered by the signature on it, that is, an alteration which is not material#
+ince, there is no predefined definition of material a lteration in the Negotiable Instruments Act, it varies from the fact to fact of the case but there are certain basic obectives which are certainly common in the different instruments which if altered would constitute the material change# *hus, if any alteration which affects the very purpose of the original instruments, that is, if it goes to the root of the instruments, it is considered as the material alteration
Chapter / I> %egitimac( of the Material Alteration *he material alterations certainly have a certain effect on the contract under which such negotiable instrument"s was made or issued# As per section 8 of the Negotiable Instrument Act, 1881, &the effect of material alternation of a negotiable instrument renders the contract void as against anyone who is party thereto at the time of ma)ing such alteration and does not consent thereto, unless it was made in order to carry out the common intention of the original parties# If such alteration is made by the endorsee, it discharges his endorsers from all liability to him in respect of the consideration thereof# It is based on the sound ustice that 1# Nobody should be permitted to ta)e chance of committing a fraud without running any ris) of loss by the event when it is detected 7# 9y the alteration, the identity of the instruments is lost, and to hold one of the parties liable under such circumstances would ma)e him liable for something, for which he would never agree# *hus, when a material alteration has been made a negotiable instrument"s, as well as the parties to the instruments are discharged# If the alteration is made by an endorser, then his endorsee is discharged from all liabilities to him# 8 It should be noted that if a material alteration is agreed to by all the parties, it becomes a new instrument which requires a new stamp.
Again +ection 88 states the acceptor or endorser of a negotiable instrument is bound by his acceptance or endorsement notwithstanding any previous alteration of the instrument#
Also, +ection 8/ tal)s about the payment of instrument on which alteration is not apparent# it states that
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213 4here a promissory note, bill of e'change or che5ue has been materially altered but does not appear to have been so altered, or where a che5ue is presented for payment which does not at the time of presentation appear to be crossed or to have had a crossing which has been obliterated, payment thereof by a tenor thereof at the time of payment and otherwise in due course, shall discharge such person or ban)er from all liability thereon6 and such payment shall not be 5uestioned by reasons of the instrument having be en altered, or the che5ue crossed# 273 4here the che5ue is an electronic image of and the truncated che5ue shall be a material alteration and it shall be the duty of the ban) or the clearing house, as the case may be, to ensure the e'actness of the apparent tenor of electronic image of the truncated che5ue while truncating and transmitting the image# 23 Any ban) or a clearing house which receives a transmitted electronic image of a truncated che5ue, shall verify from the party who transmitted the image to it, that the image so transmitted to it and received by it, is e'actly the same# rom the above definitions it can be seen that the basic concept as regards the effect of material alteration in a negotiable instrument is that material alteration avoids the instrument and if done unilaterally without the consent of the other party in a deceitful manner for one"s own vested interests nothing but amounts to an offence#/ In this regard the following has been stated in =alsbury"s Law of :ngland, &*he effect of ma)ing such an alteration, without consent of the party bound, is e'actly the same as that of canceling the deed.# +o the instrument becomes void and the party basing its claim upon it, cannot claim anything# *his result follows irrespective of the fact whether the party concerned was responsible for the alteration or whether it was made by someone else without his consent or )nowledge#
In the cases of Firm Sri Chand v. Lajja Ram and Jayantilal Lal Goel v. Zubeda Khanum, it is held that a material alteration of the instrument discharges all parties who are liable on the instrument at the time of alteration and who do not consent to such alteration#
In the case of Arumugam v. M.S ara!ai"h, it is held that if an alteration is made by erasure,
7 +hreysi +ingh, egotiable #n!trument!$ Material alteration and it! Fall%&ut!, httpHHwww#ta'indiaonline#comHC7Hinside7#phpOfilenamePbnewsQdetail#php
interlineations or otherwise in a material part of a deed after its e'ecution by or with the consent of any party thereto or person entitled thereunder, but without the consent of the party or person liable thereunder, the deed is thereby void# *hus the instrument stands invalidated as a result of material alteration as against the party whose consent was not ta)en for alteration# 9ut what is the status of the document subected to material alteration as against the person who became a party subse5uent to material alterationsO *his 5uestion was answered in the case of Rama"handran v. 'ine!an# It is held in this case that &As regards the effect of material alteration, the basic principle of law is that such a change invalidates the instrument against the person not consenting to the change# 9y alteration, the identity of the instrument is destroyed# +o, the effect of ma)ing a material alteration on a negotiable instrument without the consent of the party bound under it is e'actly the same as that cancelling the instrument# *he instrument is rendered void only as against any one who is a party thereto and not against anyone becoming a party subse5uent to the alteration# If a person indorses an altered instrument without the )nowledge of the alteration he may be liable to the indorsee# A person, who accepts an altered instrument, cannot absolve his liability on the acceptance on account of the previous alteration#. 4hether the alteration was fraudulent or innocent also ma)es a difference# In the case of aiv 9hai Nathabhai 0atel v# anchhod agunath 0atel, it is held that where there has been a material alteration in the instrument, the further 5uestions for consideration of the court are whether the alteration is fraudulent or innocent# 4here the alteration is fraudulent, the courts will not allow the plaint to be amended and the plaintiff to fall bac) on the original cause of action# 9ut where the alteration, though material, is innocent and the plaint is based on the original cause of action as well as on the document altered, the claim if properly proved can be allowed on the original cause of action# Dr if the original plaint is not on the original cause of action, it is open to the plaintiff to apply and the court to consider whether the plaintiff should be allowed to amend it# It has been held in a no of cases that if alteration is made in a document when it was in the custody of a party, that party is bound to suffer because a party who has the custody of an instrument made for his benefit, is bound to preserve it in its original state# It has also been held that a material alteration made with the consent of the other party would operate as a new agreement and as such the conse5uences of material alteration made with the consent of the other party are different from those when material alteration is made without such consent#
Chapter / > ?udicial Trends <+ Nathu %al .+ Mussamat #omti @uar 1<8734 72 $!M%R <<=;
"ACT -
*he suit was brought on +eptember 8, 1/78 by the appellants# 0laintiff e'ecuted a sale deed 2A3 in favour of defendants who in turn e'ecuted a deed 293 for conditional transfer of the properties sold to them both on 7@th Farch 18??, condition being paying the stipulated consideration amount for transfer of sold properties anytime after e'piry of period of 7@ years from date of deed 9# 9y both deeds A and 9, parties intended to create !mortgage by conditional sale" and hence, were to be regarded as single deed of mortgage# 0laintiffs while pleading specific performance of obligations under the mortgage submitted certified copy of deed 9 bearing date 7th Farch 18??# =ence, before filing the original deed 9, they made holes near to the date of agreement so that it could be read as 7 th instead of original 7@th# +econd, plaintiffs also made hole after the words &has sold. in deed 9, though word &shartia. 2conditional3 was visible#
I&E5
4hether the unilateral alterations as mentioned above were material enough to render the mortgage voidO
HE%-5
A material alteration is one which varies the rights, liabilities or legal position of parties as ascertained by deed in its original state, or otherwise varies the legal effect of the deed as originally it had# 4hen such material alteration is made unilaterally by one party without the consent of other party, it operates to ma)e the deed void from the date such alteration is made and both the parties will be discharged from their respective future ob ligations under the deed#
*he document A, sale deed and document 9, agreement to release, being part of the same transaction created the relationship of mortgagor and mortgagee between defendant and plaintiff respectively as soon as they were e'ecuted in 18??# If these unilateral alterations were to be held !material" then they would have the effect of ma)ing the agreement void# =owever, such alterations which effected ust before the pleadings, will not ma)e the whole mortgage void-ab initio so as to nullify its conveyancing effect 2under deed A, plaintiffs conveyed property to defendant, this sale deed will be subsisting and valid3, however, they will relieve the parties of their future obligations as under the mortgage, i#e# covenant by the defendants to release the property in event of depositing the amount mentioned in deed 9, would be unenforceable by law# *hough the suit for redemption of mortgage will lie 2since not whole of mortgage has become void3 but the action would be barred by limitation period of J years and will not be stipulated by deed 9 2which had given whimsical period as to when plaintiff would give the consideration anytime after 7@ years of deed3# =owever, as regards the first alteration as to date of the agreement, same date could be inferred from vernacular date mentioned in the agreement as 7@th Farch 18??# As regards the second alteration, since the word &shartia. meaning conditional was visible hence, it could be clearly implied that it was intended to be conditional sale agreement and conse5uently agreement was of nature of mortgage and not of sale agreement# *herefore these alterations were not material and hence, did not operate to ma)e the mortgage void#
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Chapter - KI
Conclusion
