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15TH NASCENT MOOT COURT COMPETITION

SYMBIOSIS LAW SCHOOL, NOTDA

Before
THE HON'BLE DISTRICT COURT OF SAKET

In the mnatter of

VIOLA
PLAINTIFF

IDUNN
DEFENDANT

MEMORIAL ON THE BEHALF OF DEFENDANT

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TABLE OF CONTENTS

LIST OF ABBREVIATIONS..

INDEX OF AUTHORITIES.
STATEMENT OF JURISDICTION.

STATEMENT OF FACTS.

ISSUES RAISED.

SUMMARY OF ARGUMENTS.

ARGUMENTS ADVANCED.

ISSUE1: WHETHER DISTRICT COURT SAKET. HAS JURISDICTION TO

HEAR THE MATTER

SPECIFIC
ISSUE 2: WHETHER THE PLAINTIFF IS ENTITLED TO

PERFORMANCE.

PRAYER..

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LIST OF ABBREVIATIONS

1. AIR - All India Reporter

2. Art. - Article
3. CPC-Code of Civil Procedure, 1908
4. Hon'ble - Honourable

5. LAAPATA Act - Lifetime (And Akaal Protocol Actualisation Technologies)

Acquisition Act, 2026
6. Ors -Others

7. PHAEDO Public Human Age Extension Delivery Organisation

8. Pvt Ltd Private Limited
9. S.- Section
10. SCC - Supreme Court Cases
11. SC - Supreme Court
12. UNTS - United Nations Treaty Series
13. V.- Versus

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INDEX OF AUTHORITIES

TABLE OF CASES

1989 SC 1239.
ABC Laminart Pvt Ltd
v AP Agencies, AIR SC 543
1. Parshottamdas, AIR 1966
Goverdhandas Kedia v Girdharilal
2. Bhagwandas Parmeshwari Devi, (1975)
1SCC 486 (SC)
Insurance Co v
3. British India SCCI
Union of India, (2018) 5
4. Common Cause v
10 SCC I
v Union of India, (2017)
K.S. Puttaswamy
5.
(1852) 42 ER 687
6. Lumley v Wagner, SCC 341
Network v WSG Cricket Pte Ltd, (2003) 4
7. Modi Entertainment Dixit, (1991) 3 SCC 655
Nandganj Sihori Sugar Co Ltd v Badri Nath
8.
Basu, (1994) 4 SCC 711(SC)
9. ONGC v Utpal Kumar SCC 235
Union for Democratic Rights
v Union of India, (1982)) 3
10. People's
4SCC 227
Percept D'Mark (India) Pvt Ltd v Zaheer Khan, (2006)
11.
Nawaz Jung, (1991) 3 SCC67
12. Rattan Chand Hira Chand v Askar
Bangur & Co, AIR 1954 SC 44
13. Satyabrata Ghose v Mugneeram
AIR 1968 SC 534
14. Sita Ram v Radha Bai, (1968)
Maharashtra, 1994 Cri LJ 1604 (Bom)
15. Ramchandra Gopalrao Dugal v State of

STATUTES REFERRED

1. The Code of Civil Procedure, 1908

a. S.20
b. S.20(c)
2. The Constitution of India
Article 21

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b. Article 23
3. The Indian Contract Act.
1872
a. S.23
b. S.56
4. The Lifetime (And Akaal Protocol
Actualisation Technologies) Acquisition Act,
2026 (LAAPATAA Act)
a. S.4(1l)
b. S.4(2)
c. S.12(1)
d. S.12(2)
5. The Specific Relief Act, 1963
a. S.14(c)
6. The Transplantation of Human
Organs and Tissues Act, 1994
a. S.19

b. S.22

INTERNATIONAL INSTRUMENTS

1. Convention Against Torture and Other

Cruel, Inhuman or Degrading Treatment or
Punishment (adopted 10 December l1984, entered into force 26 June
1987) 1465
UNTS 85
2. International Covenant on Civil and
Political Rights (adopted 16 December 1966.
entered into force 23 March 1976) 999 UNTS 17|
3. UNESCO, Universal Declaration on the
Human Genome and Human Rights (1 I
November 1997)
4. Universal Declaration of Human
Rights, UNGA Res 217A (IIlI) (10 December
1948)

MEMORIAL ON BEHALF OF DEFENDANT 5

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REFERRED:
ARTICILES
BOOKS AND LexisNexis
Performnance (Sth edn,
England, vol 44(). Specific
Halsbury's Laws of
1. Act and
2023) para 676 The Indian Contract
Fardunii Mulla,
Dinshah
Pollock and
2. Sir Frederick 2017)
5thedn, LexisNexis 2019)
Specific ReliefActs (1 Dictionary (l lth edn,
Thomson Reuters

(ed), Black's Law

3. Bryan A Garner
Policy'
sub voce 'Public

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STATEMENT OF JURISDICTION

The counsels on behalf of the Plaintiff have approached the Hon'ble District Court of
Saket, New Delhiunder Section 20 of the Code of Civil Procedure, 1908. The defendant
most respectfully refutes the jurisdiction of the District Court of Saket, New Delhi to
adjudicate the present case.
20. Other suits to be instituted where defendants reside or cause of action arises. -Subject

the limitations aforesaid, every suit shall be instituted in a Court within the local limits of
whose jurisdiction

(a) the defendant, or each of thedefendants where there are more than one, at the time of
the

commencement of the suit, actually and voluntarily resides, or carries on business, or

personally

works for gain; or

(b) any ofthe defendants, where there are more than one, at the time of the commencement
of the suit, actually and voluntarily resides, or carries on business, or personally works for
gain, provided

(c) The cause of action, wholly or in part, arises.

All of which is most respectfully subnmitted

MEMORIAL ON BEHALF OF DEFENDANT 7

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STATEMENTOF FACTS

Background
The present controversy has stemmcd from a contract between two individuals Viola, a
33-ycar-old Gurugram resident, and ldunn, a 27-year-old software cnginecer in Mumbai
regarding the transfer of "lifetime" through a new technology known as the Akaal Protocol.
The protocol, developed by ascientist by the pseudonym Henrietta, cnables inter vivo
transfer of genome-encoded biotic information, i.c., one's quantifiable lifespan, also known
as anaevitas. With its release in January 2026, the CentralGovernment enacted the
Lifetime (And Akaal Protocol Actualisation Technologies) Acquisition Act, 2026 (the
LAAPATAA Ac), which made it obligatory for the Public Human Age Extension
Delivery Organisation (PHAEDO) as the sole legal organisation for all lifetime transfers.
The Act makes such transfers legal only upon explicit and enthusiastic consent of both
parties and makes the services of PHAEDO obligatory for the enforcement of such
contracts as per the law.

Agreement Between Viola and Idunn

On the evening of March 1s, 2027, Viola, wanting to keep her identity a secret, wanted to
purchase one year of lifetime through a transaction that was not initially channeled through
PHAEDO. Annalise, her attorney, was instrumental in arranging the transaction with
Idunn, whose profile as a teetotaller and a non-smoker made her lifetime particularly
valuable in the market. The transaction called for Idunn to sell one year of her life to Viola
in return for a cash consideration of 21,60,50,000, which was a 7% premium over the
current market rate at the time. It was agreed that the formalities needed would be
undertaken at Annalise's office at Saket, New Delhi, ten days later, after which the formal
transfer of the lifetime would be done at Viola's residence in Gurugram. Annalise
proceeded to register the transaction with PHAEDO the following day, ensuring that all
fees and penalties necessary were paid in good time. However, acriticalevent occurred

MEMORIAL ON BEHALF OF DEFENDANT

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SUMMARY OF ARGUMENTS
The Defendant contests
the jurisdiction of the Saket court to hear the
submitting no substantial or material part of matter at hand,
the cause of action which arose
territorial jurisdiction. The contract was neither within ts
Saket. The invocation of this forum concluded, performed, nor breached in
amounts to forum shopping, and the
non conveniens is squarely doctrine of forum
applied. The agreement stands vitiated by
as performance would have statutory ilegaliy.
directly contravened Sections 4(1). 4(2),
LAAPATA Act, 2026. At the relevant time, the and 12 of the
compliance for off-platform transfers. Proceeding
transaction did not satisfy the mandatory
with the contract would have rendered
the Defendant liable to severe
penal consequences. The doctrine of
lex non cogit ad
impossibilia applies; the law cannot compel what it
prohibits.
The grant of specific performance in the
instant case would result in an egregious
of the Defendant's fundamental
rights under Articles 2 l and 23 of the
violation
India. The right to Constitution of
life includes the right to bodily autonomy
and freedom from forced
medical or biological procedures. Enforcing
the contract would amount to
extraction of a year of life against the Defendant's will, compelled
amounting to forced labor vwithin
the meaning of Article 23. Further, enforcing
such an agreement is in violation of India's
obligations under the UDHR, ICCPR., and CAT.
Section 14(c) of the Specific Relief Act, 1963
excludes contracts
qualifications from the remedy of specific performance. The dependent on personal
involves the bodily act and volition of the agreement in question
Respondent and is inherently personal in nature.
Contracts that require performance of personal service or are
rooted in individual skill.
trust, or consent are incapable of specific
enforcement. The present agreement squarelv
falls within this exception. Hence, the
Defendant urges the court to dismiss the Plaintiffs
claims and provide any further relief deemed
equitable under the presented circumstances.

MEMORIAL ON BEHALF OF DEFENDANT 11

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ARGUMENTS ADVANCED:

I/ THE DISTRICT COURTATSAKET HAS NO JURISDICTION TO ENTER TAIN

THE SUIT

1.1NO SUBSTANTIAL PART OF THE CAUSE OF ACTION AROSE IN SAKET

It is submitted that the district court at Saket does not possess territorial jurisdiction over
the present dispute, considering the principles laid down under section 20 of the code of
civil procedure, 1908.
Section 20(c). CPC: Subject to the limitations aforesaid, every suit shall be
instituted in a
Court within the local limits of whose jurisdiction
(c) the cause of action, wholly or in part,
arises. ?
The fulcrum of the Plaintiffs argument
rests on clause (c) i.e., a part of clause of
arose in Saket. However, it is a cardinal action
principle of procedural law that such part
substantial and integral to the dispute and not must be
merely tangential or preparatory.
The situs of contract
formation is where the acceptance is
Bhagwandas Goverdhandas Kedia v. communicated. As was held in
Girdharilal Parshottamdas, (1966) where
acceptance is received is where the contract the
is formed. The
acceptance from Mumbai. No contract Respondent expressed her
said to be the locus of
was executed in Saket. Therefore, Saket
formation. cannot be
The place of
performance of the contract was the
the Akaal Protocol
procedure was to be done. ThePetitioner's house in Gurugram, where
Laminart Pvt. Ltd. v. A.P. Hon'ble Supreme Court in A.
Agencies, (1989), held that B.C.
even where a part of
the cause of
Code of
2Code of Civil Procedure |908, s 20.
ibid.
Civil Proccdure 1908, s 20(c).
Bhaywandas Goverdhandas
Kedia v
Girdharilal Parshottamdus
(1966) AIR 166 SC
S43.
MEMORIAL ON BEIHALE OF
DDEFENDANT
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action develops at a location, it confers jurisdiction upon that court. Here the signitiCant
act the transfer of life-years -was to take place in Gurugram. Saket was only a
preparatory stopping point, not a site of legal performance or violation. Any such refusal
conveyed in Saket was, at best, anticipatory repudiation. The actual default failure to
enact the Protocol took place in Gurugram. According to accessorium sequitur
principale, the accessory act (refusal) accompanies the principal duty (performance).
Therefore, the cause of action is in Gurugram.

Saket was neither the place of formation of contract, performance, nor breach. In
ONGC r.
Utpal Kumar Basu, (1994) the Hon'ble Court cautioned against jurisdiction on the basis of
"mere sending of communication."Û Granting Saket jurisdiction would be forum shopping.
as held in British India Insurance Co. v. Parmeshwari Devi, (1975)."

1.2 APPLICATION OF FORUM NON CONVENIENS DOCTRINE

Even if this Hon'ble Court were to premise itself on assuming that a very small part of the
cause of action had been triggered in Saket, it is submitted that the suit should not be
entertained here under the doctrine of forum non conveniens.

This rule, although not specifically enshrined, was recognized by the Hon'ble Supreme
Court in Modi Entertainment Network v. WSG Cricket Pte Ltd. (2003) The Court ruled that
where there is a more convenient forum, on grounds of convenience of parties, witnesses,
and place of evidence, the present court can refuse jurisdiction in the interest of justice 8

In the present case, the Defendant is from Mumbai, and the venue of the performance was
Gurugram. All material witnesses, documents, and the actual violation are in Gurugram.
not Saket. The Saket meeting was merely logistical not an essential part of the contract
or its violation. Pleading the Plaintiff to take the Defendant to Saket, a court with no actual
connection to the dispute, would be an unnecessary inconvenience and go against fairness.

ABC Laminart Pvt Lid v AP Agencies (1989) AIR 1989 SC 1239.

6ONGCv Utpal Kumar Basn (1994) 4 SCC 7| (SC).

British India Insurance Cnv Prmeshwari Devi (1975) 1 SCC 486 (SC).
Modi Entertainment etwork v WSGCricket Pe Ltd (2003) 4SCC HL.

MEMORIAL ON BEHALF OF DEFENDANT 13

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Mumbai
are cither Gurugram (whcre the brcach happened) or
The more proper forums proccedings here
Defendant is based). It is submitted respectfully that to allow
(where the achieve no ends of
burden on the Defendant and
would place an undue procedural encourage forum
jurisdiction in such cases would
substantive justice. The exercise of
contact points.
shopping and fragment litigation on the basis of trivial
SPECIFIC PERFORMANCE OF THE
Ii] THE PLAINTIFF IS NOT ENTITLED TO
LIFETIME
AGREEMENT FOR TRNSFER OF ONE YEAROF

2.1 THE CONTRACT IS UNENFORCEABLE ON GROUNDS OF ILLEGALITY

Scction 4() of the LAAPATA Act, 2026 provides as follows:

"No person shall initiate, take part in, or carry out any Akaal Protocol activity other than
US per the provisions of this Act. "9

Section 4(2) further lays down:

"Any person who contravenes suh-section (1) shall be punishable with death or
imprisonment for life. "io

Section l12(1) mandates:

"All transactions involving the transfer of lifetime shall be conducted on the official Public
Human Age Extension Delivery Organisation (PHAEDO) platform in accordance with the
procedure laid down by regulations. "!1

Section 12(2) allows:

"LAAPATA Act 2026, s 4(1).

10 LAAPATA Act 2026, s
4(2).
LAAPATA Act 2026, s 12(0).

MEMORIAL ON BEHALF OF
DEFENDANT 14
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"O-market transactions shall be permissible only ifboth parties are duly registered with
PHAEDO and the requisie penalty ond regulatory surcharge are paid at the time of
submission. "12

The facts show that although the Plaintiff did her part in the registration and payment of
the fees, the Defendant's registration was held up because her attorney died prematurely.
Therefore, going ahead with performance on the agreed date would have been a direct
contravention of Section 4(1) and 12, subjecting the Defendant to the penal provision of
Section 4(2). Such performance of the contract in such a case would be an act prohibited
by law.

Section 23 states:

The object or consideration of an agreement is legal, unless. it is prohibited by law, or is

of sucha natre that, iflegalized, it would be contrary to public policy, or the court would
hold itto be immoral, 13

Applying this clause, the Hon'ble Supreme Court in Sita Ramnv. Radha Bai. (1968). held
that courts will not enforce a contract where performance is illegal or consists of statutory
disobedience. At the material time, the Defendant was not lavwfully able to execute the
contract as stipulated by the Plaintiff. The agreement was therefore frustrated by
supervening illegality, and enforcement of it would be against both the LAAPATA Act
and Section 23 of the Contract Act. The Plaintiff can argue that the illegality was curable
by re-execution of documents and payment of fees. It is, however, estab lished law that a
contract which is void for statutory non-compliance at the time of intended performance
cannot subsequently be revived for enforcement. The Respondent's refusal was a valid act
of legal self-preservation. The doctrine lex non cogit ad impossibilia (the law does not
compel the doing of impossibilities) squarely applies: the Defendant cannot be compelled

12 LAAPATA Act 2026, s 12(2).

13 Indian Contract Act 1872, s 23.

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to perform what would have exposed her to criminal liability. In addition, Section 56 of the
Indian Contract Act, l872 states:

"A contract to do an act which, after the contract is made, becomes impossible, or by
reason of some evet which the promisor could not prevent, unlawful, becomes void when
the act becomes impossible or nlawful. "4

In Sayabrata Ghose v. MUgneeram Bangr & Co.. (1954) the Hon'ble Supreme Court
ruled that: "Impossibility under Section 56 includes not only physical or literal
impossibility but also impracticability and legal futility that destroys the foundation of the
agreement." The passing of the Defendant's attorney made performance
non-conforming
to legal formalities, hence unlawful on the date of performance.
This supervening
impossibility rendered the contract void. The agreement also goes against the
fundamental
principles of the Transplantation of Human Organs and Tissues Act, 1994 (THOTA),
which explicitly prohibits commodification of human bodily
objects. Section 19 of
THOTA provides:

"No donor shall allow the removal ofany of

his human organs for any other
therapeutic use, "i6 than

Furthermore, Section 22 of THOTA establishes a penalizing restriction:

"Any advertisement soliciting
individuals to give, for consideration or
human organ shall be punishable... otherwise, any
and any contract entered into
be void. "17 for such purposes shall
Even though the contract is for
"lifetime," Akaal Protocol is a biological
surgical procedure and hence comes
within the protective purview of harvesting like a
THOTA.
14 Indian Contract Act 1872, s 56.

15 Satyabrata Ghose v Mugneeram

Bangur & Co AIR 1954 SC
44.
16 Transplantation of Human Organs and
Tissues Act 1994, s 19.
I7 Transplantation of Human Organs and Tissues
Act 1994, s 22.

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DEFENDANT 16
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In Ramchandra Gopalrao Dugal v. State of Maharashtra, 1994 Cri LJ 1604 (Bom), * the
Hon'ble Bombay High Court ruled that sale of any part of the body for
money
irrespective of consent-is void for violating public policy and bodily dignity.

2.2 SPECIFICPERFORMANCE VIOLATES THE

RIGHTS
DEFENDANT'S FUNDAMENTAL

Article 2| of the Constitution

states:
"No person shall be deprived of his life or
personal liberty except according to procedure
established by law. " 19

The Hon'ble Supreme Court in Common

Cause v. Union of India, (2018), ruled that
right encompasses the right to dignity, this
bodily autonomy, and freedom from
medical intervention.2º Forcing the unwanted
Defendant to undergo the Akaal Protocol after
withdrawal of consent is violative of her
right to personal freedom
constitution. It is a right that encompasses under Article 21 of the
reaffirmed in K.S Puttaswamy v. Union of autonomy, dignity and bodily integrity, as
India (2017).21
Article 23 of the Indian
constitution provides:
"Traffic in
hman beings and begar and
prohibited, and any contrvention of other similar forms of forced labour are
this provision shall be
accordance with ln, "2? an offence punishable
in

18 Ramchandra Gopalrao Dugal vState

of Maharashtra l994
19 Cri LJ 1604 (Bom),
Constitution of India, art 21.
30 Commnon Cause v Union of lrdia (2018)5
SCC 1.
21 K.S.
Puttaswamyv Union of India (2017) 10
SCC 1.
Constitution of India, art 23.

MEMORIAL ON BEHALF OF
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Tne essence of this provision is to prevent the extraction of human service under coercion.
The Defendant submits that a decree mandating the enforcement of the contract, in
definace of her will, amounts to begar in spirit. The Hon'ble Supreme Court in People's
Union for Democratic Rights v. Union of lndia, (1982), has made it clear that economic
necessity or legal compulsion cannot legalize forced labour.3 Such coercion stands in
direct contravention of the Constitution.

This reasoning is strengthened by India's international human rights treaty obligations:

Article Iof the Universal Declaration of Human Rights (UDHR) asserts that "All
human beings are born free and equal in dignity and rights."24
Article 4 of the UDHR, and Article 8 of the International Covenant on Civil and
Political Rights (1CCPR). prohibit slavery, servitude, and forced or compulsory
labour 2s

The Convention Against Torture (CAT), although not yet ratified to the fullest
extent, codifies the principle that no one must be subjected to treatment or
punishment that offends bodily autonomy or human dignity.26
Instruments such as the UNESCO Universal Declaration on the Human Genome

and Human Rights (1997) prohibit treating human life and biology as
commodities.27

Being a member to the UDHR and ICCPR, and a member of UNESC0, India is obligated
to maintain these international standards. Therefore, enforcing acontract requiring
involuntary biological sacrifice would make India liable for these commitments and
derogate the principles of human dignity and sanctity of body.

2 People 's Cnion for Democratic Rights v Union of India (1982) 3 SCC 235.

2* ibid art 4; International Covenant on Civil and Political Rights (adopted l6 December 1966, entered into
force 23 March 1976)99 UNTS 171, art 8.
26 Convention Against Torture and Other Cruel. Inhuman or Degrading Treatment or Punishment (adopted 10
December 1984, entered into force 26 lune 1987) 1465 UNTS 85.
27 UNESCO, Univer sal Decluration on the lman Genone and Iuman Rights (1| November 1997).

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Lastly, In Ratan C'hand lira

Chand v. Askur Nuwaz hy
invalidated a contract for sale of an (|991), he Supreme Court
unborn child, and it held that
human dignity are against public policy contracts contrary to
and thus not enforceable.2% The
which forces performance over current contract,
the objection of the
ominous grounds. The maxim salus Respondent, does so on equally
populi suprema lex the people's welfare is the
supreme law
should guide the Court in refusing
the very concept of bodily enforcement of a contract that imperils
dignity and voluntariness.
Therefore, this Hon'ble Court should deny
specific performance and instead order
parties to restitution, upholding the the
fair justice. Respondent's fundamental freedoms while delivering

2.3 THE
CONTRACT CANNOT BE SPECIFICALLY
ENFORCED AS IT IS
DEPENDENT ON PERSONAL QUALIFICATIONS
It issubmitted that the present agreement is barred
from being specifically enforced under
the Specific relief act, 1963. Section
14(c) of the act provides as follows:
"Acontract which is so dependent on the
personal qualifications of the parties that the
courtcannot enforce specific performance of its
material terms shall not be specifically
enforced "29

The substance of the agreement was the

transfer of a year of lifetime by the Respondent,
who was specifically chosen after careful
research by the plaintiff's agent, further attesting
to the personalized nature of the
contract. Such contracts, based on personal
the physical act of an individual, are not volition and
amenable to specific performance. The Hon'ble
Supreme Court in Nandganj Sihori Sugar Co. v.
Badri Nath Dixit (1991). reaffirmed that
contracts involving personal services cannot be enforced
by way of specific performance
and only give rise to a claim for damages,"
This rule is also endorsed by Halsbury's Laws
of England, which states that
"the court does not require persons to
enter continuous

2 Rattan Chand IHlira Chuind v

Askr Nawaz Jng (|99)3
0 Specific Relicf Act 193, s 14). SCC67.
30 Nandyanj Sihori Sugar o Ltd
v Badri Nath Dxit (19D3
SCC 655.

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personal and confidential relationships, contracts for personal service are not specifically
enforced "31

Additionally, in Percept D'Mark v. Zaheer Khan, (2006), the Hon'ble Supreme Court
refused to enforce a personal endorsement contract, stating that contracts grounded in
personal trust, skill, or volition are unsuitable for specific enforcement.** In the present
case, compelling the Respondent to undergo a life-extraction procedure, against her will,
would result in a direct assault on her bodily autonomy and dignity. Similarly, in Lumley
v. Wagner (1852), although an injunction was issued to avoid breach, the court declined to
offer affirmative performance, acknowledging the voluntariness involved in contracts
involving personal skill,33

It is thus respectfully submitted that the present contract is barred from specific
enforcement by virtue of Section 14(c) of theSpecific Relief Act, 1963. The Hon'ble Court
is urged to deny specific performance on this statutory ground alone.

31 Halsbury's Laws of England(4th edn, Butterworths 1973) vol 44. para 426
32 Percept D'Mark (lndiay Put Ltd vZaheer Khan (2006) 4 SCC 227.
33 Lumley v Wagner (I 852) 42 ER 687.

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PRAYER

Therefore, in consideration of the issues presented, the arguments advanced, and the legal
precedents set, it is humbly submitted that this Hon'ble Court may be pleased to:
1. Declare that the District Court of Saket lacks territorial jurisdiction to entertain the
present suit under Section 20(c) of the Code of Civil Procedure. 1908, as no material part
of the cause of action arose within its territorial limits:

2. Reject the Plaintiff's prayer for specific performance of the agreement dated 15th March
2027, on the following grounds:
a. The Defendant's rejection was justified due to the incomplete PHAEDO registration.
rendering the agreement unenforceable under Section 12 of the LAAPATA Act, 2026;
b. The Plaintiff failed to prove her readiness and willingness to perform her part of the
contract as required under Section l6(c) of the Specific Relief Act, 1963;
[Link] that the agreement is voidable under Section 53 ofthe Indian Contract Act, 1872,
as the Plaintiff's failure to ensure complete registration directly prevented the Defendant
from performing her obligations;
4. Award the costs of the proceedings to the Defendant; and

S. Pass such other or further orders as this Hon'ble Court may deem just and proper in the
facts and circumstances of the case.