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As per case facts, the Reserve Bank of India uncovered widespread irregularities in securities transactions during 1991-92, leading to the enactment of the Special Courts Act. This case involves complex
...transactions between Citi Bank, Standard Chartered Bank (SCB), and Canbank Mutual Fund (CMF). CMF initially sold securities to Citi Bank, providing an SGL transfer form that was later dishonoured due to insufficient balance. Subsequently, Citi Bank agreed to sell bonds to SCB, issuing Banker's Receipts (BRs). SCB then requested SGL forms, specifically CMF's dishonoured SGL form and Citi Bank's own SGL form, from Citi Bank in exchange for the BRs, which SCB accepted. SCB later sued Citi Bank, claiming non-delivery of securities and alleging fraud, arguing that the SGL forms were "useless or worthless." Citi Bank countered that SCB had voluntarily and unconditionally accepted these SGL forms as full satisfaction, thereby discharging Citi Bank's obligation. The question arose whether Citi Bank's original obligation to deliver bonds to SCB was completely discharged when SCB accepted the SGL forms in exchange for the Banker's Receipts, and whether this constituted an absolute or merely conditional satisfaction under the Indian Contract Act. Finally, the Supreme Court ruled that SCB had indeed voluntarily and unconditionally accepted the SGL forms as full satisfaction of the debt, effectively discharging Citi Bank's obligation to deliver the bonds. The Court emphasized that the return of the duly signed Banker's Receipts by SCB created a rebuttable presumption of discharge, which SCB failed to contest with sufficient evidence. It determined that Section 63 of the Indian Contract Act, which allows a promisee to accept any satisfaction deemed fit, was applicable. Conversely, Sections 41 (performance by a third person) and 62 (novation of contract) were found not to be applicable to the circumstances. Consequently, the Court allowed both appeals, setting aside the decrees previously issued against Citi Bank and CMF, and dismissed the original suits with costs, thereby upholding Citi Bank's claim of discharge.
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