Report No. 147
Cancellation of Decrees
9.1. Section 31 provides for the cancellation of "written instruments". This expression is not confined to contracts and is wide enough to cover unilateral documents such as receipts, acknowledgements, gifts and wills. It has also been held to cover awards and compromise decrees. There is, however, a doubt as to whether decrees other than compromise decrees will fall within the meaning of the expression.1
We are mentioning this in passing. We do not recommend any statutory amendment for the present and we would leave the matter open for judicial clarification, if and when an occasion should arise.
1. Shanti Prasad v. Kunj Lal, AIR 1953 PEPSU 151: Dunia Lal v. Nagendra Nath, AIR 1953 Cal 163.