Wednesday, 5 February 2014

Contract Act 1872-Free Consent-Fraud

By Asok Nadhani
5.6 Fraud
a.     Intention to deceive : As per Sec. 17, Fraud means and includes any of the following acts committed by a party to a contract, or with his connivance, or by his agents, with intent to deceive another party thereto or his agent, or to induce him to enter into the contract.
i.      Suggestion of untrue fact : the suggestion of a fact, which is not true, or believe it to be not true;
Ex. Y with an intension to deceive X falsely represented 100 quintals of cotton balls in his godown, there by inducing X to buy the godown. The contract is voidable at the option of B.
ii.    Active concealment : the active concealment of a fact by one having knowledge or belief of the fact;
Ex. Ram while working on the field of Rahim discovered some hidden jewellery and concealed the fact. Later on he managed to purchase the field from Rahim. This contract is voidable at the option of Ram. 
iii.   No intention to perform : a promise made without any intention of performing it;
iv.   Act to deceive : any other act fitted to deceive;
v.     Fraudulent : any such act or omission as the law specially declares to be fraudulent.
b.    The following acts amounts to fraud:
i.      False statement made recklessly : A false statement made knowingly or without belief to be true, recklessly or not caring whether it is true or not, with an intention to make other person act upon it.
ii.    Material fact concealed : A material fact has been concealed or fact has been partially stated so as to make it false.

5.6.1 Elements of Fraud
i.      False representation : There must be a false representation or assertion. If the representation is true when it is made, but become untrue to the knowledge of the party making it, then it must be corrected, otherwise the other Party can rescind it.
Ex. C make an untrue statement to D with the intention of inducing D to enter into a contract with him, this amounts to Fraud.
Ex. C offers to sell to D a painting as original work, which only C knows is a good copy of a well-known masterpiece. D agrees to buy thinking it original. Held, D may rescind the contract.
ii.    Material fact : The representation must relate to a material fact (which existed in the past or exists now). A mere opinion, commentary or statement is not regarded as representation of fact.
Ex. X while negotiating with Y for the sale of certain goods, tells him that the goods cost him Rs.5000. This is a statement of fact. But if he states that the goods are worth Rs.5000, this is a statement of opinion.
iii.   Intent to induce : The representation must have been made before the conclusion of the contract, with an intention to induce other party to act on it.
iv.   Reckless Act : The person making the representation knows it to be false or makes it recklessly not caring whether it is false or true. It must have been by the party or by its connivance or its agent.
v.     Other party induced : The other party must have been induced to act upon the representation.
Ex. A, a businessman, truly represented to B, a prospective buyer, that his business turnover was Rs.20 Lakhs a year. Five months later when B bought the business, it had considerably gone down on account of A’s serious illness. A did not disclose this fact to B. B may avoid the contract as A ought to have disclosed the fact.
vi.   Party deceived : The other party must have relied upon the representation and was deceived. A mere attempt to deceive is not fraud unless the party was actually deceived.
Ex. S brought an electric oven from P. The oven was defective but P had fixed it up, S did not check the woven and started using it. The oven was completely destroyed. Held, the oven was destroyed due to other cause and not for the problem which has been already fixed up by P, so S is liable to pay for the oven.
vii.  Damage : The other party acting upon the representation must have suffered loss. There is no fraud without damage.
viii. Committed by a party to the contract : It must have been committed by a party to the contract or anyone with the connivance of a party to the contract.
ix.   Knowledge of its falsity : The fraudulent act must be committed with knowledge of its falsity.

5.6.2 Non Disclosure of Fact amounting to Fraud
a.     Need not disclose all material facts : A party while entering into a contract need not disclose all material facts, but he should not actively conceal a fact.
Ex. Two traders A and B enter into a contract. A has private information of a change in prices which would affect B’s willingness to proceed with the contract, but he did not disclose. It will not affect the contract. Because, it is not essential for A to disclose the private information.
b.    However, there are statutory exceptions to the fact:
i.      Duty to speak : Having regards to the circumstances, it is the duty of the person (who remained silent) to speak out the fact.
ii.    Latent known defects : Where the seller fails to disclose the buyer of a latent known defect (not apparent in ordinary inspection) in the product being sold.
iii.   Disclosure by Trustee : A Trustee does not make full disclosure of facts to the beneficiary while entering contract with him, his silence about any materials fact amounts to fraud.
iv.   Partial disclosure : Where partial disclosure deceives the other party.
Ex. A, a businessman, truly represented to B, a prospective buyer, that his business turnover was Rs.20 Lakhs a year. Five months later when B bought the business, it had considerably gone down on account of A’s serious illness. A did not disclose this fact to B. B may avoid the contract as A ought to have disclosed the fact.
c.     Silence : Mere silence to affect the willingness of a person to enter into a contract is not fraud, unless his silence is, in itself, equivalent to speech.
Ex. P is Q’s son. P says to Q that ‘If you don’t deny it, I shall assume it that the horse is sound’ Q says nothing. Here the relation between parties would make it Q’s duty to tell P if the horse is unsound, so Q’s silence is equivalent to speech.
Ex. A, a businessman, truly represented to B, a prospective buyer, that his business turnover was Rs.20 Lakhs a year. Five months later when B bought the business, it had considerably gone down on account of A’s serious illness. A did not disclose this fact to B. B may avoid the contract as A ought to have disclosed the fact.

5.6.3 Legal consequences of Fraud
a.     Voidable : A contract induced by fraud is voidable at the option of the party defrauded. The contract remains valid until it is avoided.
b.    The aggrieved party may:
i.      Rescind : Rescind the contract within a reasonable time.
ii.    Insist on performance : He can insist on performance of the contract on the position he would have been, had the representation been true.
Ex. A woman fraudulently represented to a firm of jewellers that she was the wife of a certain baron and thus obtained two pearl necklaces on credit on some pretext with a view to buying them. She sold those necklaces to X. a third person. Held, X must restore the necklaces to jeweler.
iii.   Sue for damages : The Party whose consent was obtained by fraud may sue for damages.
c.     Loss of right : However, the aggrieved party loses his right to avoid/ rescind the contract:
i.      Where the aggrieved party could discover the truth by ordinary diligence, as a prudent man would take in his own case.
ii.    Where the party enters into the contract in ignorance of the fraud.
iii.   Where the party affirms the contract after becoming aware of fraud.
iv.   Before the contract is avoided, a third party acquires the right in the subject matter for value, acting bona fide.
v.     When a party to a contract whose consent was not freely obtained, cannot be put in the position he would have been had the represented fact been true.
vi.   A Fraud which did not cause the consent of the party to the agreement.
vii.  Where interests of third parties intervene, before the contract is avoided.
viii. Where the truth though not known to the principal was known to his agent.
d.    Restoration of Benefits : When a party rescinds a voidable contract, he shall restore (i.e., pay back) any benefit received by him under such contract, to the person from whom the benefit was received (sec. 64).
     
5.6.4 Distinction between Fraud and Misrepresentation
i.      In misrepresentation, there is no intention to deceive. In fraud, the intention is to deceive.
ii.    In misrepresentation, the party making the statement believes it to be true, while in fraud, he believes it to be untrue.
iii.   In misrepresentation, the aggrieved party may rescind the contract or insist for restitution (there cannot be any suit for damages), while in fraud, he can sue for damages also (apart from his right to rescind or restitution).
iv.   In misrepresentation, the aggrieved party cannot avoid the contract if he could discover it with ordinary diligence, while in fraud, in case of active concealment, the contract is voidable even though the aggrieved party had means of discovering the truth.

For more details, refer to Mercantile law, by Asok Nadhani, BPB Publications, www.bpbonline.com, bpbpublications@gmail.com


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