Reviewed case brief

Pandit Chunchun Jha v Ebadat Ali

AIR 1954 SC 345

The test for distinguishing a mortgage by conditional sale (S.58(b)) from a genuine sale with repurchase option is the REAL INTENTION: if a debtor-creditor relationship exists and reconveyance is conditional on repayment, it is a mortgage regardless of the document's label.

property-lawmortgageconditional-salesection-58bintention-test
Court
Supreme Court of India
Year
1954
Subjects
Property Law
Reviewed
2026-06-30

Rule established

Test for distinguishing mortgage by conditional sale from genuine sale: real intention of parties; existence of debtor-creditor relationship

Facts

    Issues

      Held

        Ratio decidendi

        How to use it in an exam

        Editorial source

        AIR 1954 SC 345

        Educational summary only. Read the reported judgment or an authorised law report before relying on the case professionally.