Madhuri Patil vs. Additional Commissioner case is a landmark case of the Indian Evidence Act, 1872. The major fundamental concept involved in this case was the concept of ‘Estoppel’, which is covered under Section 115 of the Indian Evidence Act, 1872.
Section 115 of the Indian Evidence Act, 1872: Estoppel is that rule which prohibits a person from contradicting what was earlier said by him in a court of law, which was a concept discussed in this case.
FACTS OF KUMARI MADHURI PATIL vs. ADDL. COMMISSIONER CASE:
- The plaintiff in the Madhuri Patil case wanted to take admission to an educational institution.
- For ensuring her admission, she used a ‘fake’ caste certificate, which would guarantee her selection over other candidates.
- The student succeeded. She got admitted to the institution and continued her studies.
- When the educational institution got the air about the fake caste certificate used by the student, they realized that indeed it was not authenticated. As a result, the institution canceled her admission on the grounds of forgery of the document, which was crucial for admission.
- Whether the appellant can plead the doctrine of estoppel as per Section 115 of the Indian Evidence Act, 1872?
The plaintiff contended that, as the educational institution has previously accepted her ‘fake’ caste certificate, it cannot be rejected after a certain amount of time, and therefore, she pleads estoppel.
RATIO AND DECISION:
Justices K. Ramaswamy and N. Venkatachala delivered the decision of the Supreme Court.
They held that:
- The cancellation of the social certificate issued by the Executive magistrates concerned by the scrutiny committee was legal.
- It is a fundamental duty of every citizen to develop a scientific temper and humanism and a spirit of inquiry to reform himself in his onward thrust or strive to achieve excellence in all spheres of individual and collective activity.
- School and college certificates hold no value as per the appellants, as the admission has taken place on forged grounds.
- The plea of promissory estoppel or equity has no application. Courts would be the ones to circumspect and vary in considering such cases.
- In the Madhuri Patel case, the Supreme Court of India said that if the party to whoever the representation was being projected, somehow recognizes that it was a false representation then, he/she will not be entitled to the claim of the doctrine of estoppel.
- In Madhuri Patel vs. Addl. Commissioner’s case, as the institute, the doctrine of estoppel did not recognize the representation won’t apply.
- Finally, the party which took admission to the educational institution by fraud was not permitted to continue studying in the same institution upon the claim of estoppel.
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