MANGALA WAMAN KARANDIKAR (D) TR. LRS. V. PRAKASH DAMODAR RANAD (2021) 11 SCC 451
- The recent ruling by the Supreme Court underscored the significance of Sections 92 and 95, which pertain to the inadmissibility of oral agreements and the interpretation of existing facts through documentary evidence respectively. The crux of the matter before the Court revolved around the applicability of these provisions to ambiguous documents. In elucidating its stance, the Apex Court elucidated the following criteria for assessment: When contractual terms are unequivocal, Sections 92 and 95 are not invoked.
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Contractual interpretations are wholly contingent upon the intentions of the contracting parties, with the court being tasked with ascertaining and providing the true meaning inherent in the interpretation.
- Judges Surya Kant and Aniruddha Bose expressed the view that the High Court's observations in the present case, which expand upon the scope of Section 92 beyond its legislative intent, constitute a breach of fundamental principles of legal interpretation. This stance was informed by the precedent set forth in the case of Rohitash Kumar v. Om Prakash Sharma (2012). court, whereas Section 92 exclusively addresses the parties involved in the document.
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