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Anil Kumar vs Maya Jain || AIR 2010 SUPREME COURT 229 || Case Summary


Agreement

Anil Kumar vs Maya Jain Case Summary

Case Introduction

The dispute in this case is whether there existed a separation agreement between Anil Kumar and Maya Jain. According to Anil Kumar, he was forced to sign the agreement and claimed that as a result, it was without effect.

Legal Issues

Coercion and Consent: Central to the issue of the case is the concept of coercion as defined in Section 15 of the Indian Contract Act, 1872. This distinguishes coercion from other means of persuasion and renders all agreements made under coercion, feigned or otherwise, as impermissibly lacking in free consent and therefore voidable at the behest of the shop which was found in duress.

Enforcement of Contracts: The court’s analysis on whether the said agreement satisfied the requirements of a contract brought about the importance of the element of genuine consent and the effects of coercion in the performance of contracts.

Findings of the Court

The Supreme Court held that the parties had signed the separation agreement but under duress, which makes such agreements inadmissible since there is no consent given freely by the parties or either party. 

The judgment reiterated the need to protect one’s right not to be subjected to undue influence stating that consent in domestic relations and even personal agreements is very critical.

Consequence

In this case, it can be said that the problem of coercive agreements is taken a step further, as it raises principles of Indian contract law, as the alleged coercive agenda is ever present especially in the household sphere.

Further, it aims at reducing the monopoly threat on individuals within intimate settings by calling for caution in the courts on matters of suspicion of coercion.

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