Indian Journal for Research in Law and Management

Advancing Law and Management

ISSN No. : 2583-9896

ROLE OF DOCTRINE OF FRUSTRATION IN INDIAN CONTRACT LAW

Cite this Article

PAIYYAVULA RAMYA (2026). ROLE OF DOCTRINE OF FRUSTRATION IN INDIAN CONTRACT LAW. The Indian Journal for Research in Law and Management, Volume III(Issue 9). Retrieved from https://ijrlm.com/journal/role-of-doctrine-of-frustration-in-indian-contract-law-2/

Abstract

This paper examines the application of Section 56 of the Indian Contract Act, 1872, widely known as the Doctrine of Frustration, which discharges a contract when an unexpected event makes performance impossible. By focusing on the landmark Supreme Court decision in Satyabrata Ghose v. Mugneeram Bangur and Company (1954), the study explores how Indian jurisprudence established strict boundaries for this doctrine. The court clarified that "impossibility" under Section 56 does not merely mean literal physical impossibility, but rather a complete destruction of the commercial object and underlying purpose of the contract. To evaluate how these foundational principles operate today, the paper contrasts the Satyabrata Ghose ruling with modern commercial challenges, specifically the COVID-19 lockdown lease disputes highlighted in cases like Ramanand v. Girish Soni. The comparison reveals a persistent legal tension between human empathy during financial crises and the commercial necessity for contractual stability. The analysis demonstrates that while the strict application of Section 56 can seem harsh on struggling parties—such as tenants facing zero income during lockdowns—it remains essential for maintaining predictability in business relations. Ultimately, the paper concludes that the doctrine serves as a narrow shield rather than an easy escape route, ensuring that contracts remain reliable commitments even during global disruptions.

Journal Information

The Indian Journal for Research in Law and Management
ISSN No.
2583-9896
Submit Manuscript
Licensing
All research articles published in The Indian Journal for Research in Law and Management are fully open-access. i.e. immediately freely available to read, download, and share. Articles are published under the terms of a Creative Commons license, which permits use, distribution, and reproduction in any medium, provided the original work is properly cited.
Disclaimer
The opinions expressed in this publication are those of the authors. They do not purport to reflect the opinions or views of the IJRLM or its members. The designations employed in this publication and the presentation of material therein do not imply the expression of any opinion whatsoever on the part of the IJRLM.

Article Analytics

5
Page Views
0
Downloads