Research Paper on
‘Figuring the cases on calling the parties and witnesses by the way of
Online Summons – A Case Study’
By –
Ameya Thachappilly – 18010323015
Ayan Roy -18010323034
Divyanshi Choudhary – 18010323050
Kshipra Iyer - 18010323068
Div – A, B.A.LLB
Symbiosis Law School, Hyderabad
Symbiosis International University, PUNE
In
August, 2019
Under the guidance of
Mr. Pankaj Umbarkar
Assistant Professor
1
Appendix ‘B’
CERTIFICATE
The project entitled “ Figuring the cases on calling the parties and witnesses by the way of
Online Summons – A Case Study” submitted to the Symbiosis Law School, Hyderabad for
Law of Crimes I: Penal Code as part of Internal Assessment is based on my original work carried
out under the guidance of Mr. Pankaj Umbarkar from July,2019 to September 2019 . The
Research work has not been submitted elsewhere for award of any degree.
The material borrowed from other sources and incorporated in the research paper has been duly
acknowledged.
We understand that we ourselves would be held responsible and accountable for plagiarism, if
any, detected later on.
Signature of the Candidates Signature of Faculty-in-Charge
Date: 23/09/2019 Date: 25/09/2019
2
LIST OF CASES Appendix ‘C’
ACKNOWLEDGEMENT
We would like to express my sincere gratitude and indebtedness to Mr. Pankaj Umbarkar for his
enlightening lectures. I would also like to express my sincere gratitude to our teaching staff for
guiding
BOOKSme the path towards gaining knowledge.
We would like to thank the Library Staff of Symbiosis Law School, Hyderabad as well for their
co-operation.
Signature of the CandidateS
Date: 23/09/2019
3
• N. Yovas v. Immanuel Jose
• Ram Vishal alias Vishali Kachhawala v. Dwarka Prasad Jaiswal
• Central Electricity Regulatory Commission vs National Hydroelectric Power Corporation
Ltd.
• Tata Sons Limited & Ors vs John Does
• Kross Television India Pvt Ltd & Another vs Vikhyat Chitra Production & Others.
• Sir John Woodroff & Ameer Ali, Commentary on The Code of Civil Procedure, 1908 (Delhi Law
House, Delhi, 6th edn. Vol-2, 2013)
• N.K. Acharya, Guide to C.P.C (Asia Law House, Hyderabad, 2nd edn. 2012)
• Sir Dinshaw Fardunji Mulla, Code of Civil Procedure (Ashoka Law House, New Delhi, 3rd edn.
2013)
• Takwani, C.K. & Thakker M.C., Code of Civil Procedure, 1908 (Eastern Book Co. Lucknow, 8th
edn. 2018.)
4
Appendix ‘D’
Page 1 Title page (Appendix ‘A’)
Page 2 Certificate (Appendix ‘B’)
Page 3 Acknowledgement (Appendix ‘C’)
Page 4 List of cases
Page 5 Index
Page 6 Chapter I
Page 8 Chapter II
Page 11 Chapter III
Page 15 Chapter IV
Page 17 Bibliography
5
CHAPTERIZATION
Chapter I talks about the introduction to the Civil Procedure Code, 1908, the meaning of
summons and their usage . Chapter II talks about the different types of summons and aims at
introducing Online Summons Chapter III talks about their usage under CPC, its components and
cases where it is used and Chapter IV talks about improvements, current situation and
conclusion.
INTRODUCTION
Our country has provided for several laws that lay down a process to institute every case within a
proper and eligible court of law, the primary two case procedure compendiums are known
commonly as the Criminal Procedure and Civil Procedure Code. As the name suggests, the civil
procedure code deals with all those cases which do not fall under the characteristics of being
termed as a criminal case, essentially cases revolving around all civil matters. When it comes to
any kind case of one of most the fundamental parts that every case must follow is the
‘Summoning’ of the individuals who have instated this case and those against whom that specific
case has been instituted against.
Summons themselves are an ancient idea and have been a part of the legal procedure since
archaic times, just like how legal systems and law itself changes with the change in time
similarly the form or type of summons used to keep up with the modern times has also changed
drastically. Advancement in technology has played the catalysing factor here and has moulded
the direction in which summons are evolving into.
WHAT IS THE CIVIL PROCEDURE CODE, 1908?
The Code of Civil Procedure, 1908 is essentially the premier codified law that directs and
overlooks the entire procedural system of Indian Law; however, this code is only limited to civil
cases and does not include criminal law. The code expands into two parts, the first part
containing 158 sections while the second part includes the first schedule containing around 51
orders and rules. The history of the civil procedure dates back to the mid 1800’s wherein the
legislative council of India had proposed to enact Code of Civil Procedure inn 1858, this
received official assent from the then Governor-General in March 1859. This code did not last
for a long time and was replaced by the Code of Civil Procedure, 1877, but this too did not fulfil
the requirements of time and large amendments and hence here had been a large portion that had
6
yet to be improved. Another Procedure of Civil Code was introduced in 1882 but however its
rigidity was a cause for concern. The requirement of a flexible code so as to provide greater
effectiveness to meet the evolving problems was the need of the hour at that point in time, to
tackle all these issues the Code of Civil Procedure1 1908 was enacted. It did take 26 long years
to come up with a solid structure but eventually this structure amalgamated amendments and was
flexible enough to evolve and prevail through time.
Among all changes instituted within the Code of Civil Procedure, 1908 the code was
substantially amended in 2002, for the primary purpose of reducing time required to dispose a
case off. In 2016 this code was amended again but this time the provisions targeted to bring
about a limit for the cases and their values that could have been instituted within the court and
the specific courts that could deal with the cases coming up to some specific value. This
amendment clarified the different values that every cased is determined by and accordingly the
high court had the power to turn over any judgement provided by these courts that were below
the position of the high court.
WHAT IS ‘SUMMONS’?
Summons are defined as - “A summon is a document issued from an office of a court of justice,
calling upon the person to whom it is directed to attend before a judge or an officer of court for a
certain purpose. It is a written order that legally obligates someone or something to attend a court
of law at the specified date.”1
A summon is essentially a document that is issued by the house of law for the appearance of a
person or for the production of a document or item that may be vital to the proceedings of the
law. In civil law they are mostly accompanied by a complaint that has been filed with respect to
the same issue. According to the Civil Procedure Code, 1908 a summons primary objective is to
call upon those people or that document that plays a vital role in that round of the courts
proceedings, in simpler language it6 is an invitation to testify or bring a testamentary document
to support the case that is ongoing in the house of law. According to natural law no one can be
condemned unheard, “audi alteram partem” 2, all those party to a suit have all the freedom to use
legal procedure in order to prove their innocence or to prove the guilt of others, involving
1
Concise Oxford Dictionary(1990) at p. 1395.
2
Lectures on Administrative Law, 2012, Lecture IV.
7
documents and witnesses are an integral part of forming a strong defence or an offense, using
this logic summons plays a vital role in the function of legal procedure within India.
According to the Civil Procedure Code, 1908, it states that the court has the power to appoint
specific people or call upon them to attend a proceeding of the court at the specified date and
time, partie4s too must have a list of those they would like to call upon as witnesses and provide
proper information to the legal officers so that the witnesses can receive the summon required for
attending the session that they have been called upon. However, the calling party too has to
justify as to why they would like a specific individual person to be summoned and to provide the
court with proper reasoning. The primary reason behind this is so that the court is aware and has
a record of who is attending which proceeding and for what purpose, only after the court deems
that the witness to be summoned has value to the case shall they allow for a summon to be sent.3
If the court fails to find any reasoning, they are obliged to not provide a summon, such power of
the court was decided by the case of N. Yovas v. Immanuel Jose4
Just like documents and people, public records are also equally important when it comes to
forming a part of one’s suit, the constitution has provided for the Right to information as a
fundamental right and also there exists an entire act known as the Right To Information Act,
2005 whose main aim is to provide people with the information they rightly deserve at their own
pleasure. A party is free to file an application in order to summon public documents that are
relevant to their position in a suit, the court of law will again view it to find any malice or
inconsistencies but their admission cannot be outright denied and must be attain once they have
been appropriately summoned, as held in the case of Ram Vishal alias Vishali Kachhawala v.
Dwarka Prasad Jaiswal5
TYPES OF SUMMONS
Summons are of the forms mentioned below:
1. Summon For Disposal Of Suit.
2. Summon For Settlement Of Issues.
3. Summon To Appear In Person
4. Summons In A Summary Suit.
3
Sec 27, Code of Civil Procedure, 1908
4
AIR 1996 Ker 1
5
AIR 2006 MP 68
8
5. Summons For Judgement In A Summary Suit.
6. Notice To The Person Who, The Court Considers, Should Be Added As Co-Plaintiff.
7. Summons To Legal Representative Of A Deceased Defendant.
8. Order For Transmission Of Summons For Service In The Jurisdiction Of Another Court
9. Order For Transmission Of Summons To Be Served On A Prisoner
10. Order For Transmission Of Summons To Be Served On A Public Servant Or Soldier
11. To Accompany Returns Of Summons Of Another Court
12. Summon To Witness
13. Warrant Of Arrest Of Witness
14. Warrant Of Committal.
WHAT ARE THE CURRENT ISSUES, LOOPHOLES AND BARRIERS FACED BY
EXISTING MEDIA OF SUMMONS?
The existing modes of Summons that have been laid down under Section 62 include three basic methods
of service of summons. These are broadly personal service of summons (where a police officer or an
officer of court actually physically serves the summons to the person in question), substituted service
include any other methods like mail, or giving the summons to a third party when the defendant is not
present and publication of a notice in a newspaper.
Each of these modes of service of summons come with their own problems and barriers. The first method
of personal service is usually the most effective as there is usually less scope for any tampering, or illegal
interference to take place. It ensures that the defendant is completely aware of a claim against him, and
ensures that a notice has been successfully given. However, there is and has been scope for there being
malpractices with regards to false summons, malpractice by officers or third-party interferences. a
concept called ‘sewer service’ has been coined with regards to the same. This refers to when there has
been a disruption to the administration of justice. It is built on the theory of the server “tossing the papers
into the sewer” or not delivering the notice to the proper party. This is a fraud, and anyone who
participates in such a fraud, especially an attorney, will be faced with consequences including being
disbarred. If there are cases of false affidavits asserting that the delivery of the papers has been
successfully done, the person involved in such a lie will be guilty of perjury.
Substituted services are better than the personal method of service of summons from the point of view of
the defendant receiving summons. It ensures that even if the defendant is not present, he or she can be
reached through other means like post or through his relatives. It also allows for copies of the paper to be
sent to his last known address which allows for there to be higher chances of the defendant receiving the
9
summons. However, the problem with substituted services lies in the fact that in most cases there needs to
be a personal attempt made first and only then can substituted services follow. This can lead to a waste of
man power and time. Further, this method too can fall prey to malpractice by third parties and
interference in the postal services.
Publication in a newspaper required the notice to be published in at least one newspaper that is
generally circulated where the defendant is located, or where the court is. It also requires
repeated publications to increase the chances of it being seen by the defendant.
Publication as a method proves to be cumbersome when there arises the problem of whether the
defendant will actually read the notice or not. The rationale behind this is to ensure that the
notice is served to the defendant by any means. Due to the high probability of the defendant not
reading the newspaper, this method of service of summons is usually done only with the
permission of the court when the plaintiff successfully shows that there has been no other
method of service that can be affected. The biggest problem with regards to this method is that it
is expensive, and is the least effective method. It is also strenuous on the plaintiff. Summons, as
aforementioned, are often not served on time due to shortage of manpower, and more
challenging problems like dealing with unlawful delays and unresponsive defendants. Therefore,
it is crucial that there must be an alternate method of summons that addresses the various
loopholes and issues that are present with regards to the existing modes of summons.
ONLINE SUMMONS AND HOW DID THEY CAME TO EXIST.
The concept of Online Summons is something that has developed in the modern times due to the
increasing usage of the internet and the effectiveness of the internet with regards to transactions and
communication. It is only right for the unparalleled speed and effectiveness of technology to be integrated
into the judicial system, especially with regards to service of summons which has proven to be, at times,
cumbersome and ineffective. Using the internet to summon a defendant is inexpensive and relatively
much faster than any other type of summons. It is also easy for summons over the internet to meet the
standard requirements of summons as per the Code of Civil Procedure. Though personal service is
preferred by courts in most cases, online summons decrease the gap with regards to malpractice and
delay. Furthermore, it helps overcome problems relating to locating the defendant.
In India, serving summons using electronic means have been present for a while. There have been various
questions before the court with regards to the validity of such methods of summons. Important legislative
10
changes in the procedural laws have been implemented in India to address issues involving earlier
methods of service of summons. In 2002, the Code of Civil Procedure was amended to include electronic
means of serving summons in Rule 9 and Rule 9A. The question that arises with regards to online
summons is whether it is a constitutionally valid means of summons. Under substituted service of
summons, the rule states that service can be made in any manner that the Court thinks fit. This has a very
wide scope and the Bombay High Court has observed that courier, email and WhatsApp are examples of
acceptable means of summons. The court has also opined that the service is neither an empty formality
nor procedural ritual but the soul of the service is to have the knowledge of the proceedings to the
defendant or the contesting party6
In Central Electricity Regulatory Commission vs National Hydroelectric Power Corporation Ltd7 the
court allowed for the service of notice to be served by email along with other modes of service. The
Mumbai High Court in KlS and Industries Ltd. V. Mannalal Khandelwal and the State of Maharashtra
Through the Office of the Government Pleader8 stated that to avoid delay services like emails should also
be included while serving summons.
The Financial Commissioner of Court in Haryana was the first to order summons via WhatsApp.
Following this, Justice Gautam Patel set a precedent in Bombay by stating that "It cannot be that
our rules and procedure are either so ancient or so rigid (or both) that without some antiquated
formal service mode through a bailiff or even by beat of drum or pattaki, a party cannot be said
to have been 'properly' served. The purpose of service is put the other party to notice and to give
him a copy of the papers. The mode is surely irrelevant. We have not formally approved of email
and other modes as acceptable simply because there are inherent limitation to proving service.
Where an alternative mode is used, however, and service is shown to be effected, and is
acknowledged, then surely it cannot be suggested that the Defendants had 'no
notice'...Defendants who avoid and evade service by regular modes cannot be permitted to take
advantage of that evasion."9
6
Justice Mridula Bhatkar
7
[(2010) 10 SCC 280]
8
Criminal Writ Petition No. 1228 of 2004
9
MANU/MH/1228/2017
11
In Tata Sons Limited & Ors vs John Does 10summons via WhatsApp was permitted by the Delhi
High Court, which was also upheld in Kross Television India Pvt Ltd & Another vs Vikhyat
Chitra Production & Others11. Justice Surabhi Sharma Vats of the Delhi High Court also further
stated that the double tick on WhatsApp was considered a valid delivery of the summons.
It is important to note that the power to decide whether to give summons via electronic means lies with
the court.
HOW AND WHAT ROLE DO THEY PLAY IN LEGAL PROCEDURE?
The idea of online summons in India has wide possible implications in the legal system. At first glance it
provides for an easier way of service of summons as compared to other modes. It will significantly reduce
the strains involved in physically delivering mails and is much more effective as it will be a faster method
and more secure. Online summons has a wide range of possibilities. Service could be through electronic
mail (along with digital signatures), which is easily traceable and can be effectively protected as well to
prevent malpractices. Furthermore, since a single user is easier to locate and has secure access through his
account, it is reasonably more assured that the owner of the account (the defendant) will receive the
service. It also has wider implications for the legal system as it is indicative of a possibility of the judicial
system slowly progressing towards a paperless system which can prove to be more effective in the whole
process of the judiciary. Through the case laws it can be seen that the Indian legal system is ready to
accept changes to make sure that the summons is served effectively. However, an essential aspect that is
to be remembered when considering Online Summons, is that online means are not going to replace
regular modes, but will only help the process of the courts.
ADVANTAGES AND DISADVANTAGES OF ONLINE SUMMONS
Recent report states that India harbours around 566 million internet users and this number is expected to
reach around 627 million by the end of this year12. The extensive popularity of internet is due to its
features of unparalleled speed and efficiency in communication and gathering of information. It has
earned its centrality in each person’s life, a feature which can be used to improve efficiencies in the field
of law too. One area where law and internet technology could be combined is that of service of summons.
Serving of summons is an important part of any suit as only after such a summon is served properly can a
court exercise its personal jurisdiction over the person it is addressed to. The delivery of summons is
etched out in Order V Rule 9 of the Civil Procedure Code, 1908. Along with the attributes of internet
10
CS(COMM) 1601/2016
11
MANU/MH/1228/2017
12
21st I-CUBE edition
12
being commonly and widely used, it is also fast and inexpensive making it an effecting method for
serving summons. The use of electronic media or internet to service summons does not render the other
methods obsolete. It only acts as an alternative in case of failure of serving summons by the traditional
methods. However, at the present age internet service may overpower and become superior to the other
forms of service. The use of this internet service effected through instant messages, email id, etc might
result in bringing about an actual notice than traditional mail or personal services in certain
circumstances. This is because, the frequency of people checking their electronic communications is far
greater than the checking of a summon sent via post. The possibilities of this post being unread in the
addressed person’s mailbox and also the probability of not being able to trace the location of such a
person substantiates the above point.
One of the major advantages of using online methods for serving summons is the fact that it facilitates
court proceedings resulting in expediting the delivery of justice. Since right to speedy trial is a
fundamental right of a citizen the above factor substantiates and encourages this fact. The
communications given through online methods are addressed to the person required before the Court and
this communication directly reaches him as such electronic communications are mostly on the mobile
phones of people, making it accessible whenever and wherever. The traditional mail on the other hand
may be on the inclined path of being lost during transit. Few other fallbacks with regard to the traditional
methods are the non-availability of the person in the given address and any un-notified shift in location.
Moreover, when a traditional mail is sent it goes to a mail box or room which caters to a number of
people, however in regard to internet account it caters only to that specific person. Therefore, a reasonable
presumption can be inferred that when a summon is sent on an online account, it is only the addressee
who receives it. The plus point that can be clearly marked with the use of Instant messaging as a mode of
summon is the possible notice that the person received and read the sent message, however such a
verification cannot be done with the traditional methods. Internet service surely has the potential of being
a more secure space, making it more reliable than the forms employed in the past. Electronic mails and
documents attached on web sites can be authenticated by way of Digital signatures which is much harder
to forge than the traditional signatures. The possibility of forging a signature for a document received
through post or fax is greater, indicating the digital signature being a safer option.
One major advantage of using online media is the drastic cut down on costs. For instance, if summons is
sent from an account already made and purchased for, then such summons is nearly penniless as
compared to the cost to be spent on first class mail and/or personal service. As mentioned above, the use
of such online methods constitutionally arises in situations when the other modes fail to bring about the
13
notice. In the case Tata Sons Ltd & Ors v. John Does13, unable to reach one of the defendants on his
physical address, summons was sent via WhatsApp message, SMS and email. The Court held this valid
as, firstly there was no other way of reaching him and secondly the use of online communication also
hastens the process and in nowhere hinders the judicial process. Online summon was the only reasonably
calculated cost-efficient way of bringing about a notice to the defendant.
Keeping all the advantages on one side there does exist a black side to this too. At this age, on one hand
there is rise of technology which facilitates the life of the people by making it more accessible, effective
and convenient, on the other there is a sect of technology which works against the goodwill of the people.
In the context present here, the advanced technology can be used to escape the receiving of summons too.
For example, there happens to be hacked versions of WhatsApp which help in shadowing the fact that a
person has read the message.14
The possibility of deleting or losing emails is another drawback to the use of online methods.
Furthermore, any error with the system leading to data being loss is a factor to be considered.
Comparing the pros and cons of online summons, the weightage towards the advantages is way more than
its disadvantages. However, it does not indicate that the Courts overlook these aspects and focus on the
fruitful part alone. Similarly, the presence of few issues shouldn’t hold back the Courts from effectuating
such an important and necessary decision. In a nutshell, online summons offer security, tracking, deliver
confirmation, and authenticity of the sender as well as the receiver. They are efficient, secure, reliable,
and in some cases even constitutionally required.15 Nevertheless there has to be a mid-ground formed
between the pros and cons where the main focus is the protection of the rights of the citizens.
WHAT ISSUES AND PROBLEMS DO ONLINE SUMMONS FACE?
As it is clear by now what is online summons and how they came into existence. There is no doubt about
the credibility of its application as it makes the legal procedure faster and is convenient in all essence. In
spite of all this many drawbacks can be also attributed to the methods of serving online summons. It is a
well settled fact that there are three modes of service of summons, as given explicitly under section 62 of
the said legislation.
Firstly, personal service of summons wherein the competent authority which is directed by the court of
law, physically serves the summons in person to the defendant in question. Secondly method talks about
13
Tata Sons Ltd & Ors v. John Does, CS(COMM) 1601/2016.
14
https://blog.ipleaders.in/summons-whatsapp-legal-proceedings/
15
Rachel Cantor, `Internet Service of Process: A Constitutionally Adequate Alternative?’ ( Vol.66 No.3 pp. 943-
967)
14
substituted service which means any other method of informing other than the first one that is by sending
in an email or serving the summons in question to a third party due to the absence of the defendant and
lastly summons can be served in the manner of publication of a notice in the newspaper. Everything has
its pros and cons, so do these methods. Talking about the first method not only is it very convenient for
the court of law but also makes sure that the law of the land is rightly upheld. This form makes sure that
the wrongdoer in question is made aware in person and there is surety of the notice being delivered to
him. However, when one talks about false summons, malpractices come into question and it provides
space to the illegal usage of power conferred upon the competent authorities by the court of law. “Sewer
Service” is a concept which has come to light due to these malpractices in question. This concept literally
means putting any kind of obstruction or hindrance in the administration of justice. To put it in layman’s
language, it stands for not serving the notice to the required person. There is no reasonable doubt ab out
the fact that this act would amount to fraud and the person doing such an act would be held accountable
for his deeds in question. And especially if such a person is an attorney then in such a case he would have
to face legal punishments, it’s upon the discretion of the court and if at all the court decides to cancel his
license, then the attorney in question can get disbarred; also in cases of giving false affidavits whereby it
is claimed that there is successful delivery of the papers, then such a person would be booked for the
offence of perjury under the law. Substituted services ensure that even in cases of absence of the
defendant the process of serving summons would not stop as he would be made aware through other
means such as sending a post or mail or informing about the summons to any one of the relatives of the
defendant. Its ambit is wider than the first method as the papers are sometimes even sent to the last
existing address of the defendant. The problem with this kind of method is that such a mode cannot be
complied with until and unless personal attempt is made. This leads to wastage of time, eventually leading
to delay in administration of justice because of which courts usually don’t prefer such a method. There is
also scope of interference in postal services and illegal practices can even be done by third parties. The
last method is the least effective amongst all. It requires that the notice in question be published in at least
one of the newspapers, whereby the defendant resides or where the competent court of law is. It becomes
a tiring process for the plaintiff as he is under an obligation to serve repeated publications in newspaper
just to ensure that the defendant gets or reads the notice. The main problem with such a kind of method is
that there are less chances of him reading the newspaper because of which courts usually don’t allow for
such methods unless plaintiff can show that all the other methods to inform the defendant have been
exhausted, this kind of method is painstaking for the plaintiff.
Thus, it is a well settled fact that serving summons on time is really important for quick administration of
justice and due to all the drawbacks pointed out; it becomes very important to look for different and
15
alternative methods of serving summons that can help the courts to deliver justice on time and without
delay of any kind.
CONCLUSION
It is a well settled fact that serving of summons on time to the competent authority is extremely
imperative to make sure that as such there is no obstruction in the administration of justice. The core
notion of justice is that what is right should be done at the earliest, thus if any of the links is weak the
entire system gets affected. It is established that summons can be served in various methods and online
mode being one of them, has been the development of recent times. It becomes the prime duty of the
competent authority to make sure that the summons is served on time so that the belief the citizens have
in the judicial system of the country continues to exist. Online summons have both advantages and
disadvantages as rightly pointed out; on one hand such a method is very convenient and easier for the
court of law as there is less wastage of time and manpower but what is equally to be seen is that
malpractices can even be carried out here. One of the online methods, which is publication of notice in the
newspaper is a very tiring and cumbersome process for the plaintiff, his resources are used up which
surely does not support the idea of justice which is to deliver justice without getting into picture the
economic factors. This is one of the reasons that the courts of law established in India rarely allow for
such a method and if at all it does it is mainly because of the fact that all the other options get exhausted.
Thus, it is the need of the hour that there are some other alternatives in serving of summons. At a time
when India as a nation has passed some landmark judgments and has gained attention worldwide, and has
undoubtedly progressed a lot; it is high time India had some concrete methods in place. It is a well settled
fact that online summons have been beneficial if one looks at the bigger picture but a lot needs to be done
to ensure smooth and quick administration of Justice.
16
BIBLIOGRAPHY
BOOKS
• Sir John Woodroff & Ameer Ali, Commentary on The Code of Civil Procedure, 1908 (Delhi Law
House, Delhi, 6th edn. Vol-2, 2013)
• N.K. Acharya, Guide to C.P.C (Asia Law House, Hyderabad, 2nd edn. 2012)
• Sir Dinshaw Fardunji Mulla, Code of Civil Procedure (Ashoka Law House, New Delhi, 3rd edn.
2013)
• Takwani, C.K. & Thakker M.C., Code of Civil Procedure, 1908 (Eastern Book Co. Lucknow, 8th
edn. 2018.)
ACTS
Civil Procedure Code, 1908.
ONLINE SOURCES
• https://legal-dictionary.thefreedictionary.com/Service+of+Process
• http://www.mondaq.com/india/x/708880/Telecommunications+Mobile+Cable+Communications/
Changing+Face+Of+Serving+Summons+From+Post+To+Whats+App
LAW REVIEWS
• “Internet Service of Process: A Constitutionally Adequate Alternative? “Rachel Cantor Vol. 66,
No. 3 (Summer, 1999), pp. 943-967 (25 pages) Published by: The University of Chicago Law
Review
ARTICLES
• India: Changing Face Of Serving Summons: From Post To What's App Last Updated: 8 June 2018
Article by S.S. Rana & Co. Advocates
• Service of Summons- Court can Consider Service through Email or WhatsApp- Bombay
High Court
• https://www.vakilno1.com/legal-news/service-of-summons-court-can-consider-service-of-
through-email-or-whatsapp-bombay-high-court.html
• https://blog.ipleaders.in/summons-whatsapp-legal-proceedings/
17
