LAW OF CONTRACTS

Elaborating the Rights of An Unpaid

Seller against Goods

Submitted by: Samewanhi Submitted to:

Roll No : 18158 Dr. Sangeeta Taak

Group No : 24 Assistant Professor of

Law
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ACKNOWLEDGEMENT

I am feeling highly elated to work on the topic “Rights of unpaid seller

against the goods“ under the guidance of Dr. Sangeeta Taak, my faculty of LAW OF
CONTRACT. I am very grateful to her for his exemplary guidance. I would like to enlighten
my readers regarding this topic and I hope I have tried my best to pave the way for bringing
more luminosity to this topic.

I also want to thank all of my friends, without whose cooperation this project
was not possible. Apart from all these, I want to give special thanks to the librarian of my
university who made every relevant materials regarding to my topic available to me at the
time of my busy research work and gave me assistance. And at last I am very much obliged
to the God who provided me the potential for the rigorous research work.

And finally yet importantly I would like to thank my parents for the financial
support.
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TABLE OF CONTENTS

1. Introductio

................................................................................................................................... 4

2. Definition under the rights of the unpaid seller.....................................................5

a) Definition of Unpaid Seller as per Section 45 of the Sale of Goods Act…………………5

3. Rights of Unpaid Seller......................................................................................... 7

a) Right Of Lien (Ss. 47)...............................................................................................7

b) Right To Stoppage In Transit (Ss. 50).......................................................................10

c) Right Of Resale (Ss. 54)..........................................................................................12

4. Case Laws…………………………………………………………………………………..12
a) Ram Saran Das Raja Ram and Anr. V. Lala Ram Chander………………………………...12

b) Pawan Hans Helicopters Ltd. v. AES Aerospace..................................................................15

c) Antim Dubey. v. The State of Madhya Pradesh....................................................................15

d) Contship Container Lines Ltd. v. D.K. Lall............................................................... 16

5. Conclusion…………………………………………………………………………………..17

6. Bibliography………………………………………………………………………………..19
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I. INTRODUCTION

Contracts or agreements related to the sale of goods are governed under the Sale of Goods Act 1930.
This act came into effect on the 1st of July 1930 in the whole of India except the state of Jammu and
Kashmir. Let us learn some important definitions and provisions of the act.

Sale of commodities constitutes one of the important types of contracts under the law in India. India
is one of the largest economies and also a great country where and thus has adequate checks and
measures to ensure the safety and prosperity of its business and commerce community. Here we
shall explain The Sale of Goods Act, 1930 which defines and states terms related to the sale of
goods and exchange of commodities.

The Sale of Goods Act, 1930 herein referred to as the Act, is the law that governs the sale of goods
in all parts of India. It doesn’t apply to the state of Jammu & Kashmir. The Act defines various
terms which are contained in the act itself.

‘BUYER" means a person, who buys or agrees to buy goods,

“GOODS" means every kind of movable property other than actionable claims and money; and
includes stock and shares, growing crops, grass, and things attached to or forming part of the
land which are agreed to be severed before sale or under the contract of sale;

“SELLER" means a person who sells or agrees to sell goods.

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2. DEFINITIONS UNDER THE RIGHTS OF UNPAID SELLER AGAINST

GOODS

Definition of Unpaid Seller as per Section 45 of the Sale of Goods Act

“(1) The seller of goods is deemed to be an unpaid seller within the meaning of this Act – (a)
when the whole of the price has not been paid or tendered; (b) when a bill of exchange or other
negotiable instrument has been received as conditional payment, and the condition on which it
was received has not been fulfilled by reason of the dishonor of the instrument or otherwise.

(2) In this chapter, the term seller includes any person who is in the position of a seller, as, for
instance, an agent of the seller to whom the bill of lading has been endorsed, or a consignor or
agent who has himself paid, is or directly responsible for, the price.”1

A seller who has only received a part of the price is also an unpaid seller. Where the seller has
received a negotiable instrument, like a bill of exchange, promissory note or cheque, for the
price, he is not an unpaid seller. But if, before he has delivered the goods, the negotiable
instrument is dishonoured, and then he becomes an unpaid seller and may exercise his rights.
This is so because a negotiable instrument is always presumed to have been received as a
conditional payment and the condition is not fulfilled when it is dishonoured. The position is
briefly summed up by Mellish, LJ in the case Gunn v. Bolckow, Vaughan & Co:

If the bill is dishonoured before delivery has been made, then the vendor’s lien revives; or if the
purchaser becomes openly insolvent before the delivery actually takes place, then the law does
not compel the vendor to deliver to an insolvent purchaser.

The security afforded by the Act to an unpaid seller are also extended to “any person who is in
the position of a seller, as, for instance, an agent of the seller to whom the bill of lading has been
certified, or a consignor or agent who himself has paid or is directly responsible for, the price”
This is illustrated in the case J.L. Lyons & Co Ltd v. May & Baker Ltd. In this case, L Co, sold a
quantity of citric acid crystals to one P, who resold the goods to M & B. The goods were not of
1
Bare Act available at https://indiankanoon.org/doc/651105/
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the contract quality. L Co, therefore, agreed to take them back and refunded the price to P. The
latter gave a cheque to M & B, in refund of the price. This cheque was dishonoured and,
therefore, M & B sought to retain the goods till their price was refunded.

But it was held that they could not do so. They were held bound to return the goods as the court
refused to believe “that a person who has bought and paid for, and afterwards rejected the goods,
is a person like an unpaid seller.”
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3. RIGHTS OF UNPAID SELLERS AGAINST THE GOODS

RIGHTS OF THE UNPAID SELLER (SS. 46)

“Definition of unpaid seller’s rights as per section 46 – (1) Subject to the provisions of this Act
of any law for the time being in force, notwithstanding that the property in the goods may have
passed to the buyer, the unpaid seller of goods, as such, has by implication of law –

(a) A lien on the goods for the price while he is in possession of them;

(b) In case of the solvency of the buyer a right of stopping the goods in transit after he has parted
with the possession of them;

(c) A right of resale as limited by this Act.

(2) Where the property in goods has not passed to the buyer, the unpaid seller has, in addition to
his other remedies, a right of withholding delivery similar to and co-extensive with his rights of
lien and stoppage in transit where the property has passed to the buyer.”2

These rights of an unpaid seller do not depend upon any agreement, express or implied, between
the parties. They arise by the implication of law. They are some of the incidents attached by law
to a contract of sale.

These rights generally presume that the property in the goods has passed to the buyer, and, in
order to assure the same rights and protections to the seller where the property has not passed,
Section 46(2) specially states that where the property in the goods has not passed to the buyer,
the seller would have the same rights of lien and stoppage in transit which he would have had as
if the property had been passed.

2
Bare Act available at https://indiankanoon.org/doc/651105/
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RIGHT OF LIEN (SS. 47)

“Definition of the seller’s lien as per section 47 – (1) Subject to the provisions of this Act, the
unpaid seller of goods who is in possession of them is entitled to retain possession of them until
payment or tender of the price in following cases, namely: (a) where the goods have been sold
without any stipulation as to credit; (b) where the goods have been sold on credit, but term of
credit has expired; (c) where the buyer becomes insolvent.”3

(2) The seller may exercise his right of lien notwithstanding that he is in possession of the goods
as agent or bailee for the buyer.

Lien is the right to retain possession of goods until certain charges due in respect of them are
paid. The unpaid seller has the right to retain the goods until he obtains the price. Section 47
provides that the unpaid seller of goods who is in possession of them is entitled to retain his
possession until payment or tender of the price. Where the goods are sold on credit, the right of
lien is suspended during the term of credit. But on the expiry of that term, if the goods are still in
the possession of the seller, his lien is restored.

The right of lien is correlated with the possession and not with title. Thus, where the seller has
transferred to the buyer the documents of title to the goods, his lien is not defeated as long as he
remains in possession. Even where the seller issued to the buyer delivery of orders thereby
converting himself from an owner into a bailee for the buyer, his lien was not defeated. For
section 47(2) clearly declares that “the seller may exercise his right of lien notwithstanding that
he is in possession of the goods as agent or bailee for the buyer.”

The right of lien exists only for the price of the goods. The seller is not entitled to lien for any
other charges such as charges for storage or the like. It has been held by the House of Lords in
Somes v. British Empire Shipping Co that where the price has been tendered, the seller cannot
claim to retain the goods further for the expenses incurred by him on storage during the period
that he was holding the goods in the exercise of his lien.

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 http://mercantilelaws.blogspot.in/2012/05/rights-of-unpaid-seller.html
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Part Delivery (Ss. 48)

Part Delivery as defined by Section 48 – Where an unpaid seller has made part delivery of the
goods, he may exercise his right of lien on the remainder, unless such part delivery has been
made under such circumstances as to show an agreement to waive the lien.

Where an unpaid seller has delivered a part of the goods, he may exercise his lien on the
remainder. In Grice v. Richardson, the sellers had delivered a part of the three parcels of tea
comprised in the sale, and they had not been paid for the part which remained with them. They
were allowed to keep it till payment of the price. Where, however, a part of the goods are
delivered under circumstances which show an agreement to waive the lien, the seller cannot then
retain the remainder. In other words, where delivery of a part is intended as a delivery on the
whole, the lien is lost. “If both parties intend it as a delivery of the whole, then it is a delivery of
the whole; but if either of the parties does not intend it as a delivery of the whole, if either of
them dissents, then it is not a delivery of the whole.” The party, who alleges that part delivery
was intended to operate as delivery of the whole, has to prove that fact.

Where the contract envisages delivery of goods by installments, the buyer’s default in paying
one installment does not entitle the seller to stop delivery of the rest of the installments unless:
(a) the buyer has become insolvent or (b) the buyer’s default amounts to repudiation of the whole
contract.

Where the goods are at the time of sale in the custody of a third person, they are considered to be
in the seller’s possession for the purposes of his lien until the third person attorns to the buyer
and thereby becomes a bailee for the buyer.

Termination of Lien (Ss. 49)

Termination of Lien has been defined in Section 49 – (1) The unpaid seller of goods loses his
lien thereon – (a) when he delivers the goods to a carrier or other bailee for the purpose of
transmission to the buyer without reserving the right of disposal of the goods; (b) when the buyer
or his agent lawfully obtains possession of the goods; (c) by waiver thereof.
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(2) The unpaid seller of goods, having a lien thereon, does not lose his lien by reason only that he
has obtained a decree for the price of the goods.

Lien is linked with possession and is lost when possession is lost. Section 47 accordingly
provides that the unpaid seller of goods loses his lien in the following cases – (1) when he
delivers the goods to a carrier or other bailee for the purpose of transmission to the buyer without
reserving the right of disposal of the goods; (2) when the buyer or his agent lawfully obtains
possession of the goods; (3) by waiver of the lien.

Sub-section (2), however, provides that the unpaid seller does not lose his lien by reason only
that he has obtained a decree for the price of the goods.

RIGHT TO STOPPAGE IN TRANSIT (SS. 50)

“Section 50 confers the right of stoppage in transit upon the unpaid seller. It says: “Subject to the
provisions of this Act, when the buyer of goods becomes insolvent, the unpaid seller, who has
parted with the possession of the goods, has the right of stopping them in transit, that is to say, he
may resume possession of the goods as long as they are in the course of transit, and may retain
them until payment or tender of the price.”4

The first requirement is that the seller should be unpaid, second that the buyer should have
become insolvent and third that the property should have passed to buyer, for, if the seller
reserves the right of disposal, the goods remain his property, and, therefore, under his lien.
Lastly, the goods should be in the course of transit. The first three requirements are questions of
fact which can be easily ascertained. The last requirement is also a question of fact, but this fact
is sometimes difficult to ascertain.

4
Bare Act available at https://indiankanoon.org/doc/651105/
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DIFFERENCES BETWEEN RIGHT OF LIEN AND RIGHT OF STOPPAGE IN

TRANSIT5

Right of Stoppage in
Right of Lien
Transit
1. The unpaid seller can exercise this
1. The unpaid seller can exercise this right
right if he has lost possession of the
only if he keeps possession of the goods.
goods.

2. This right can be exercised when the 2. This right is exercised only when the
buyer is able to pay but does not pay. buyer is insolvent.

3. This right comes to an end the moment

3. This right commences only when the
possession of the goods is lost by the unpaid
seller has lost possession of the goods.
seller.

4. It is a right to retain possession. 4. It is a right to regain possession.

Duration of Transit (Ss. 51)

Section 51 of the Sale of goods Act (1930) defines duration of transit. It says – (1) Goods are
deemed to be in course of transit from the time when they are delivered to a carrier or other
bailee for the purpose of transmission to the buyer until the buyer or his agent in that behalf takes
delivery of them from such carrier or other bailee.

5
https://accountlearning.com/rights-unpaid-seller-goods-lien-stoppage-transit-re-sale/
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(2) If the buyer or his agent in that behalf obtains delivery of the goods before their arrival at the
appointed destination, the transit is at an end.

(3) If, after the arrival of the goods at the appointed destination, the carrier or other bailee
acknowledges to the buyer or his agent that he holds the goods on his behalf and continues in
possession of them as bailee for the buyer or his agent, the transit is at an end and it is immaterial
that a further destination for the goods may have been indicated by the buyer.

Goods are deemed to be in the course of transit from the time when they are delivered to a carrier
or other bailee for the purpose of transmission to the buyer, until the buyer or his agent takes
delivery of them. Thus transit ends when the goods are delivered to the buyer or his agent.

When Seller’s Rights are Defeated (Ss. 53(1))

Seller’s consent as defined in section 53(1) – Where the buyer sells or makes other disposition of
the goods with the consent of the seller that is binding on the seller. The assent contemplated by
the sub-section must be “such an assent as in the circumstances shows that the seller intends to
renounce his rights against the goods. It is not enough to show that the fact of the sub-contract
has been brought to his notice, and that he has assented to it, merely in the sense of
acknowledging the receipt of the information.” This was pointed in Mordaunt Bros v. British Oil
& Cake Mills Ltd. In another case it was held that their lien was defeated by the sale as the
transaction was carried out with their previous assent.

Transfer of documents of title (Section 52) – When the seller has issued to the buyer documents
of title to the goods and he has sold or pledged the goods by transferring the documents of title,
then in the case of sale, the seller’s right of lien and stoppage in transit are defeated and, in case
of pledge, his rights become subject to the pledge. It is necessary that the transferee should act in
good faith and should have given value for the goods. He should not at the time have notice of
the fact that the original seller is still unpaid and has rights against the goods.
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RIGHT OF RESALE (SS. 54)

Section 54 states that sale is generally not rescinded by lien or stoppage in transit – (1) Subject to
the provisions of this section, a contract of sale is not rescinded by the mere exercise by an
unpaid seller of his right of lien or stoppage in transit.

“(2) Where the goods are of a perishable nature, or where the unpaid seller who has exercised his
right of lien or stoppage in transit gives notice to the buyer of his intention to resell, the unpaid
seller may, if the buyer does not within a reasonable time pay or tender the price, resell the goods
within a reasonable time and recover from the original buyer, damages for any loss, occasion to
buy his breach of contract, but the buyer shall not be entitled to any profit which may occur on
the resale. If such notice is not given, the unpaid seller shall not be entitled to repay such
damages and the buyer shall be entitled to the profit, if any, on the resale.”6

The seller may expressly resolve the right of resale, in case the buyer makes a default. In such
case, no notice of resale is required, to be given. The contract is automatically rescinded when
the seller resells the goods. In such a case, he does not sell as an unpaid seller, but as the original
owner of the goods. 

6
 http://mercantilelaws.blogspot.in/2012/05/rights-of-unpaid-seller.html
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4. CASE LAWS

Ram Saran Das Raja Ram and Anr. V. Lala Ram Chander
“Appellant and his partner entered into contract to purchase one tank of mustard-oil with
condition of 1/2 per cent leakage. Respondent was proprietor of 'J' Oil Mill and the respondent
dispatched one tank wagon of mustard oil in contract. The respondent drew hundi for Rs. 30,874
on account of price of oil dispatched. The appellant repudiated contract wrongfully and refused
to honor hundi and to receive R/R from Bank and to take delivery of oil. The respondent could
realize Rs. 25,186 by resale of oil after adjusting R/R Bank charges, sale commission and other
expenses incidental to sale of oil. Respondent filed suit for recovery of amount against appellant.
Appellants resisted suit on various pleas, including challenge to jurisdiction of Courts The main
plea, however, was that there was no completed contract between parties in respect of sale and
the Respondent's suit for recovery of Rs. 6,434 was decreed with costs against appellant with
interest at 4 per cent per annum from date of suit. Hence instant appeal - Whether Trial Court
was justified in allowing respondent's suit for recovery of damages. Held, it was significant that
when plaintiff was examined as PW. 8 on issues on the merits, no point was sought to be made
on basis of earlier statement and he was not even questioned with reference to previous statement
hence the Court was right in holding that there was complete contract between parties. In case of
contract which expressly reserved right of re-sale on buyer's default, when goods were re-sold on
such default, original contract was thereby rescinded, but this would not prejudice any claim for
damages which seller may have under law. Appellant had committed breach of contract in not
taking delivery of goods and challenge was made on dispatch of goods. PW.3/employee of 'J' Oil
Mills had corroborated PW. 2 by swearing that tank was loaded. PW.2 has deposed that on
Appellant's refusal to take delivery of goods witness and others tried to persuade appellants to
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take delivery of goods. It was clear that 'J' Oil Mills notified to appellant that arrangement ought
to be made to take delivery of goods within 24 hours in default of which necessary steps would
be taken to dispose of goods at market rate. In notice goods had been described to be Appellant's
goods and sold at risk and responsibility of Appellant. Passing reference had also been made and
appellants' challenge to decision was without merit and was repelled. Amount of damages
decreed by Court must necessarily be affirmed –The appeal was dismissed.”7

Pawan Hans Helicopters Ltd. v. AES Aerospace

Petition filed u/s.9 of Act to restrain respondent or its agents from alienating, encumbering suit
goods and in allowing petitioner to remove said goods from warehouse of M/s Sagar
Warehousing Corporation, it was held that the petitioner does not have any privity of contract
with either M/s Fly Jac Forwarders Transporters or M/s Sagar Warehousing Corporation
therefore question of petitioner being liable for charges sought to be raised by M/s Fly Jac
Forwarders Transporters and / or by M/s Sagar Warehousing Corporation does not arise.
Agreement dated 16/06/1999 along with its addenda would only be regarded as an agreement to
sell within contemplation of Section 4 (3) of Sale of Goods Act, 1930 and not as a sale. No sale
has taken place and, therefore, petitioner continues to have title over goods in question even
though same are not in its possession - A person cannot have lien on his own goods although
petitioner cannot exercise any lien in respect of said goods, nor can it ask for stopping goods in
transit as contemplated u/s.46 (1) (b), petitioner can certainly ask for return of goods being
owner thereof because no sale has taken place and respondent is not interested in completing
sale. Hence petition was disposed of.

Antim Dubey. v. The State of Madhya Pradesh

“Complainant lodged a report that applicant had entered into an agreement to purchase one 10
wheeler truck for a consideration amount of Rs. 13,75,000/-, out of which Rs. 5,85,000/- was
paid to complainant and remaining amount of Rs. 7,90,000/- was to be paid to Finance Company
by applicant - Thereafter, applicant neither paid remaining amount to Finance Company nor has
paid to complainant - Complainant has sent various notices to applicant to deposit amount but of

7
Ram Saran Das Raja Ram and Anr. V. Lala Ram Chander 1967 Indlaw DEL 161; AIR 1968 DEL 233
 16

no avail, thus, he has committed criminal breach of trust therefore FIR was filed u/s. 406 of IPC -
Hence, instant application - Whether, FIR filed against applicant is liable to be quashed.
Held, it is clear that where seller has delivered property to buyer and a part of consideration
amount has not been paid by buyer, then unpaid seller has lien over said property. There is
nothing in Act, which prohibits a Juvenile to enter into any transaction. Juvenile cannot claim
any exemption from provision of IPC. Therefore, he cannot be criminally prosecuted for a
criminal breach of trust. Allegations, which have been leveled against present applicant, are that
he has purchased a truck from complainant and has made a part payment of consideration
amount and has not paid amount of Rs. 7, 90,000/- either to Finance Company or to complainant
and applicant has also not returned truck to complainant. Thus, it is clear that where purchaser
after obtaining delivery of a property has to pay either entire or part consideration amount to
seller, then unpaid seller will have lien over said property and under these circumstances, it can
be said that by not making payment of remaining consideration amount and by constantly using
property so delivered by seller, act of buyer would certainly amount to criminal breach of trust
because position of buyer would be that of trustee so long as he does not pay entire consideration
amount. Further, whether applicant was juvenile on date of agreement or not is a question of fact,
which cannot be decided in these proceedings. Application dismissed.”8

Contship Container Lines Ltd. v. D.K. Lall

“In the present case, the contracts of sale was on f.o.b. basis even when the contract of insurance
proceeded on the basis that the transportation between the seller and the purchaser and meant to
be covered by the policy would be on c.i.f. basis. While in the case of c.i.f. contract the seller in
the absence of any special contract is bound to do certain things like making an invoice of the
goods sold, shipping at the destination, etc., in the case of f.o.b. contracts the goods are delivered
free on board of the ship. Once the seller has placed the goods safely on board at his cost and
thereby handed over the possession of the goods to the ship in terms of the bill of landing or
other documents, the responsibility of the seller ceases and the delivery of the goods to the buyer
is complete. The goods are from that stage onwards at the risk of the buyer.

8
Antim Dubey v State of Madhya Pradesh and another Madhya Pradesh High Court, 2018 Indlaw MP 1575; 2018
(2) JabLJ 368
 17

The seller had, in the present case reserved no right or lien qua the goods in question. In the
absence of any contractual stipulation between the parties, the unpaid seller’s lien over the goods
recognized in terms of Sections 46 and 47 of the Sale of Goods Act, 1930 stood terminated upon
delivery of the goods to the carrier. The goods were from that stage held by the carrier at the risk
of the buyer and the property in the goods stood vested in the buyer.”9

The National Commission was, therefore, right in Holding that the seller had no insurable
interest in the goods thereby absolving the Insurance Company of the liability to reimburse the
loss, if any, arising from the misdelivery of such goods.

9
Contship Container Lines Ltd. v. D.K. Lall and others, A.I.R. 2010 S.C. 1704
 18

5. CONCLUSION

When delivery of goods is made by the seller, and acceptance is made by the buyer, the contract
of sale is complete in so far as executing the sale is concerned, but there may be nevertheless,
outstanding rights in either party. The right to enforce payment by the seller, where payment was
not a condition precedent to passing the title, and the right in the buyer to hold the seller for
delay in delivering the goods, where there is no express waiver of damage shown by the buyer,
or where the circumstances of acceptance do not show an intention to waive damages of delay by
accepting the goods. An acceptance under compulsion would not thereby waive damages
suffered because of delay. Acceptance of the goods does not ordinarily conclude the buyer, as to
a warrant made in reference to the goods, but if by the terms of the contract of sale acceptance is
to conclude the buyer on this point, the contract governs. The contract may also properly provide
that notice be given to the seller of any defects in the goods sold, within a reasonable time and
the effect of the retention of the goods beyond that time without notice or complaint, would be to
deprive the purchaser of relief.

An unpaid seller in addition to these duties and liabilities have some other moral duties such as
to check for the possible reasons of non-payment and rectify them in case he finds any error on
his part. Thus, it must be understood that the unpaid seller cannot arbitrarily exercise his 3 given
rights but must also provide reasonable and appropriate opportunity to the buyer to rectify his
errors and thus ultimately fulfill the contract in a better-coordinated way.

In the project the researcher has highlighted the various aspects of the rights of the unpaid seller
against goods .in the commercial world a seller and buyer have lots of mutual rights and duties
towards each other, which define the dynamics of the commercial world. In such a situation
where a seller is unpaid, it is very essential and very obvious indeed to impart some rights
towards such seller .In this project the researcher has tried to highlight these very rights and the
dimensions which such right carry with them.
 19

The researcher has tried his level best to dig deep into the project topic and do justification to it.
The Researcher has also acknowledged and cited the entire source authentically as far as
possible.

It was really an enriching experience to work on the above dimensions of Sales of Goods Act,
which the researcher is quite sure to have led to opening of new windows for thought, and
rejuvenation of the grey cells. He requests to encourage such Endeavour’s even in future.
 20

6. BIBLIOGRAPHY

a) Book: Contract II Along with Sale of Goods Act and Partnership Act, Dr. S.K. Kapoor
b) Book: Law of Contract and Specific Relief, Avtar Singh
c) Bare Act, The sales of Goods Act, 1930
d) Website: www.scconline.com
e) Website: Indiankanoon.org
f) Website: westlawindia.com