POSSESSION AND ITS VARIOUS KINDS

PROJECT SUBMITTED IN THE PARTIAL FULFILMENT OF THE COURSE

TITLED – JURISPRUDENCE - II

JURISPRUDENCE-II

SUBMITTED TO: - SUBMITTED BY: -

DR. MANORANJAN KUMAR NAME: SAJAL SANATAN
ASSISTANT PROFESSOR OF LAW SEMESTER: VI,

ROLL NO: 2149

COURSE: B.A.,LLB (HONS.)

SESSION: (2019-2024)

MARCH-2022

CHANAKYA NATIONAL LAW UNIVERSITY

NYAYA NAGAR, MITHAPUR, PATNA - 800001

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 ACKNOWLEDGEMENT

The present project on the ”Possession And Its Various Kinds” has been able to
get its final shape with the support and help of people from various quarters. My
sincere thanks go to all the members without whom the study could not have come
to its present state. I am proud to acknowledge gratitude to the individuals during
my study and without whom the study may not be completed. I have taken this
opportunity to thank those who genuinely helped me.

With immense pleasure, I express my deepest sense of gratitude to Dr.

Manoranjan Kumar , Faculty of Jurisprudence , Chanakya National Law
University for helping me in my project. I am also thankful to the whole
Chanakya National Law University family that provided me all the material I
required for the project. Not to forget thanking to my parents without the co-
operation of which completion of this project would not had been possible.

I have made every effort to acknowledge credits, but I apologies in advance for any
omission that may have inadvertently taken place.

Last but not least I would like to thank Almighty whose blessing helped me to complete the
project.
THANKING YOU,

NAME : SAJAL SANATAN

ROLL NO. : 2149

COURSE : B.A.LLB (Hons.)

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 DECLARATION
I hereby declare that the work reported in the B.A.LLB (Hons.) Project Report entitled
“Possession and its various kinds” submitted at Chanakya National Law
University is an authentic record of my work carried out under the supervision of
Dr. Manoranjan Kumar
I have not submitted this work elsewhere for any other degree of diploma. I am
fully responsible for the contents of my project report.

SIGNATURE OF CANDIDATE

NAME OF CANDIDATE : SAJAL SANATAN

CHANAKYA NATIONAL LAW UNIVERSITY ,

PATNA

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 TABLE OF CONTENT

S.No Topic Page

No.
Acknowledgement 2
I. Introduction
1. Aims and Objective
2. Hypothesis
3. Research Methodology 5-7
4. Method of research
5. Research Question
6. Method of Writing
7. Limitation

II. About the term Possession

8-9

III. Elements Of possession 10-12

IV. Kinds of Possession 13-15

V. Concept Of Possession In India 16-18

VI. Conclusion 19

Bibliography 20

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 I. INTRODUCTION
Physical control of a thing by a person is a fact which is external to and independent of Laws.
When laws came into existence, this fact, known as ‘possession’ was taken into account in
the sense that certain advantages are attached to the possessors . In Roman laws the chief of
these were1:.

(a) Possession was the basis of certain remedies, especially the possessor interdicts. Even a
wrongful possessor was protected, not only against the world at large, but also against the true
owner who dispossessed him without due process of law.

(b) Possession was an important precondition in the acquisition of ownership in various

ways.
(c) In the law of pledge, possession of the thing pledged constituted the creditor’s security
without any presumption of ownership.

These apply substantially in English law as well where there is also the advantage that the
possessor may exceptionally confer a good title on another though he has none himself.
In both systems there are other advantages besides these2.
If the idea of possession had remained wedded to physical control, the position would have
been relatively simple. Difficulties arose when it became necessary, because of the widening of
legal activities, to attribute to persons who were not actually in control some or all of the
advantages that were enjoyed by the persons actually in control.
Tradition and technicality combined to complicate the matter.

Traditionally, possession was the basis in law of these advantages. They attached to man because
he had physical control, which was synonymous with possession, but when it became necessary
to give the same benefits to a man who was not in control, ‘possession’ came to be ascribed to
him without the need for physical control. Reasoning then took the form that whenever a man
has these advantages, this must be because he has possession.

1 Dias, Jurisprudence Aspects of Law P. 272. Retrieved on 12 march , 2021. 16:19

2 Gleanwill Williams , Learning the law. Retrieved on 12 march ,, 2021. 16:23

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The consequence was to bring about a contrast between ‘actual holding’ and ‘possession’ as well
as a shift in the meaning of the term ‘possession’. Physical control 3 came to be distinguished
from possession under the nomenclature of ‘custody’ or ‘detention’. A person is said to be in
‘Custody’ where the holder either lacks full control or else has no animus to exclude others, for
customer examining a ring in the presence of the jeweler. It simply means to take care and keep
anything for a temporary period which belongs to another e.g., the property of the master in the
custody of the servant. Mere custody therefore is insufficient to constitute possession. And the
Roman term ‘detentio’ means full physical control in fact which for some reason is not regarded
as possession in law. Or it means to withhold or to keep in custody the goods from a person
lawfully entitled to the possession of such goods.

Aims and Objectives :

The Researcher aims to fulfill below objectives through this project :

1. The main aim of this project is to study the term possession.

2. To study about the concept of possession in India.

Research Methodology :

The Researcher will be relying on Doctrinal method of research to complete this project.

Hypothesis :

1. The Researcher assumes that there must be a intention in to exercise that physical
control over the property.
2. Possession is an evidence of Ownership.

Sources of Data

3 Prof. S.N. Dhyani, Jurisprudence- a study of Indian legal system P. 300. Retrieved on 12 march ,, 2021. 16:34

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For this study, doctrinal research method was utilised. Various articles, and books
were used extensively in framing all the data and figures in appropriate form, essential
for this study.

Research Question :

1. What are the kinds of Possession?

2. What is the Concept of possession in India?

Method of Writing :

The method of writing followed in the course of this research paper is primarily analytical.

Limitation of the study :

The Researcher as a student has completed the project , he has access to a limited
area and having a limited time.

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 II. POSSESSION AND ITS DEFINITION
It is said that in legal terminology there is no word more ambiguous in its meaning than
possession whether considered in relation to immovable or movable property.

"Possession4" literary means physical control over a thing or an object. It expresses the closest
relation of fact that can exist between a thing and the person, who possess it. In law, possession
means it includes not only physical control over a thing but also an intention to exercise that
physical control. Example: A has an article in his hand. In other words, he is in possession of that
article. The person who is in possession is called a 'Possessor'. In human life, consumption of
material things is very essential and it would be Impossible without the position of the material
things. Therefore the concept of possession is of utmost practical importance in human life.

It is not only an abstract and highly imaginative concept but it is also most difficult and
controversial concept. Its nature, scope, extent, and limits vary from time to time and system to
system. It is a variable term having different meaning depending upon the circumstances in
which this is used.

In law possession means a fact or condition of a person having such control of property that he
may legally enjoy it to the exclusion of other except against the true owner or prior possessor.

An old proverb says,‘it is nine point of law”, which implies that he who has conscious
control of an object need only surrender his control in one who can establish superior claim in
law. That is, possession constitutes ninety percent of ownership.

To a layman possession implies a relation to an object which involves exclusion of other person
from enjoyment of it.

Oxford English Dictionary5 says, ‘the visible possibility of exercising over a thing such contact
as attaches to lawful ownership. The detention or enjoyment of a thing by a person himself or by

4 Dias, jurisprudence(3rd Edition) P. 334. Retrieved on 12 march ,, 2021. 16:35

5 Gleanwill Williams , Learning the law. Retrieved on 12 march ,, 2021. 16:39

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 another in his name, the relation of a person to a thing over which he may at his pleasure
exercise such control as the character of the thing permits to the exclusion of other persons.

Bentham says, ‘possession is to recall the image which presents itself to the mind when it is
necessary between two parties which is in possession of a thing and which is not’.

Maine says, ‘physical detention with the intention to hold the thing detained as one’s own’.

Ihering6-
He takes a sociological view of the concept of possession and is of the opinion that the element
of animus possidendi is not material and cannot serve as test of legal possession. But if the view
of Ihering is accepted it would provide no answer to the question as to why a thief can claim
possession of a thing which he has stolen but not a servant who is possession of goods. Thus,
simply, intention is also a material element of legal possession.

According to him, possession means that contact with an object which involves the exclusion of
other persons from the enjoyment of it. Possession denotes physical contact resumable at will. In
other words, it does not signify mere physical detention but physical detention coupled with the
intention to hold the thing detained

"Possession" literary means physical control over a thing or an object. It expresses the closest
relation of fact that can exist between a thing and the person, who possess it. In law, possession
means it includes not only physical control over a thing but also an intention to exercise that
physical control. Example: A has an article in his hand. In other words, he is in possession of that
article. The person who is in possession is called a 'Possessor'. In human life, consumption of
material things is very essential and it would be Impossible without the position of the material
things. Therefore the concept of possession is of utmost practical importance in human life.

6 V.D. Mahajan, Jurisprudence & Legal Theory 308 (Eastern Book Company, Lucknow, 5th edn., 1987). Retrieved
on 12 march ,, 2021. 16:41

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 III. ELEMENTS OF POSSESSION

Both in English and Roman laws possession has two distinct elements. They are:

1. Physical control or power over the object possessed called corpus possessini , and

2. Intention or will to exercise that power, called animus possidendi

Both these are necessary necessary to constitute possession.

The term corpus or physical control the power to use means the power to use the thing
possessed and the thing possessed and the existence of grounds for existence of grounds for the
expectation that the possessor’s use will not be interfered with the intent consists the desire and
the will to use thing consists the desire and the will to use thing so possessed. A person cannot be
said to be in possession of a thing unless he has animus possidendi. Markby in this context says;
‘there are physical element and mental element in the legal conception and in order to constitute
possession in a legal sense there must exists not only the physical power to deal with things as
we like and to exclude others but also the determination to exercise that power or control on our
exercise that power or control on our own behalf’.

Corpus7 implies two things, namely.

i) Possessor’s physical relation to the res i.e the object; ii) The relation of the possessor to the
rest of the world i.e. Physical control 8 of the thing lies at the bottom of possession. Possession
must consist in the undoubted control over a thing to the exclusion of others. Possession must be
direct, physical and actual and not merely symbolic or fictitious. However direct contact need not
be necessary with the thing although it is true that most of the things that we possess are in direct
contact with us. For example a man walking along the road with a bundle sits down to rest and
place his bundle on the ground at a short distance from him. No one thinks of doubting that the
bundle remains in his exclusive

7 V.D. Mahajan, Jurisprudence & Legal Theory 308 (Eastern Book Company, Lucknow, 5th edn., 1987). Retrieved
on 12 march ,, 2021. 16:45

8 Dr. N. V. Paranjape, Studies in Jurisprudence and Legal Theory 413 (Central Law Agency, Allahabad, 8th edn.,
2016). Retrieved on 12 march ,, 2021. 16:46

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possession not possession not symbolically but really and actually., therefore, is not necessary
for possession.. It is rather the possibility of dealing with the possibility of dealing with a thing as
we like and of excluding others. According to Holland and keeton 9 the question whether corpus
(physical relation) exists or not depends among other things upon the nature of the thing itself
and the probability that others will not interfere with the enjoyment of it. Thus corpus may be
secured by: secured by:

a. Continued physical control of the thing;

b. Presence near the thing;

c. Exclusive knowledge of the situation of the thing,

d. Continuous possession of the thing unless it is disturbed by some physical force or violence.

A man who leaves home and goes to neighboring town for his business still retains possession of
his land or house. So is the case with movable and domestic animals which live in domestic state.
As regard wild animal which are in the wild state are only in our possession as long a s long as
they are in our captivity. A wild animal that has that has been wounded by us mortally is not in
our possession until we have laid hold of it. Possession therefore, lasts so long as there is any
physical control over things and ceases when that control ceases. The second element of corpus
is that the possessor must have the ability to exclude others. There is no hard and fast rule
regarding the amount of power to exclude others. Therefore, ‘physical control’ does not mean
‘physical power’ to exclude others. Even the weakest person may have the corpus element
(physical control). It depends more upon the general expectation that the possessor must have the
possessor must have the ability to exclude others. There is no hard and fast rule regarding the
amount of power to exclude others. There is a case on this point.

In R v. Chissiers10 , a person came to a shop and asked for a particular a particular kind of cloth
(linen). The shopkeeper handed over some piece of cloth to him but before any sale was
completed, he ran away with it. This was held to be larceny as there was no change of possession
until he ran away. It is clear from this case that the corpus of possession is not necessary
synonymous with the physical power to exclude others.

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Animus9: Another aspect is mental element without which the physical control would remain
only as a mere fact having no legal consequence. Animus is the conscious intention of an
individual to exclude others from the control of an object. The mental element in possession may
be manifested in the following ways:

a. The person holding the property need not be the owner and may exercise animus to exclude
others on behalf of the owners. A tenant or a morgagee, e.g., may have possession no less than
that of the owner h have possession no less than that of the owner himself. (it may be described
as elf. (it may be described as representative possession)

b The animus to exclude others need not be in the interest of the possessor or on his own behalf
but in the interest of bailee or lessor. A carrier of goods, a servant or agentor a trustee may have
true possession (by having corpus as well as animus) though he makes no claim to the thing
possessed on his own behalf but on behalf of the owner.

c. Animus to exclude others need not be specific. A person having a library has the
possession of every book in the library though he might have forgotten the existence of some of
the books.

d. The animus to exclude others need not be based on a legally enforceable claim. It may be
the result of a wrongful act. Thus if ‘B’ steals goods from ‘A’ and ‘C’ in turns teals it from ‘B’,
then although ‘A’ has a right of claim against both ‘B’ and ‘C’ yet in spite of this ‘B’ as spite of
this ‘B’ as a prior possessor (although a prior possessor (although a thief) against ‘C’ and theor
thief) against ‘C’ and theoretically ethically he can legally recover possession of the goods from
can legally recover possession of the goods from ‘C’.

e The animus to exclude others need not be absolute. Sometimes a person may possess a piece of
land notwithstanding the fact that some other person or even the public at large, possess a right
of way over it.

9 Scruton, Roger (2007-02-07). The Palgrave Macmillan Dictionary of Political Thought. ISBN 9780230625099.
Retrieved on 12 march ,, 2021. 17:19

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 IV. KINDS OF POSSESSION

Possession may be of .may kinds. It may either be corporeal or incorporeal; mediate or

immediate, constructive, concurrent possession, adverse possession and so on adverse possession
and so on.

Mediate and Immediate possession10: In law one person may possess a thing for on account of
someone else. In such a case the latter is in possession by the agency of him who so holds the
thing on his behalf. The possession thus held by one man and another may be termed mediate,
while that hitches acquired or retained directly or personally may be distinguished as immediate
or direct.

It is also known as indirect possession. It has three kinds. The first is that which I acquire through
an agent of servant; that is to say, through someone who holds solely on my account and claims
no interest of his own. In such a case I undoubtedly acquire or retain possession, as for example
when acquire or retain possession, as for example when I allow my servant to use my tools allow
my servant to use my tools in his work, or when a warehouse man who holds them on my
account, or when I send my boots to a shoemaker to be repaired. In all such cases, though the
immediate possession is in the servant, warehouse man the mediate possession is in me; for the
immediate possession is held on me; for the immediate possession is held on my account. The
second kind of mediate possession is that in which the direct possession is in one who holds both
on my account and on his own, but who recognizes my superior right to obtain from him the
direct possession whenever I choose to demand it. That is to say, it is the case of a borrower or
tenant at will. I do not loose possession of a thing because I have lent it to someone who
acknowledge my title to it and is prepared to return it to me on demand, and who in the
meantime holds it and looks after it on my behalf. There is no difference in this respect between
entrusting a thing to a servant or agent and entrusting it to a borrower. . It is the case in which
the case in which the immediate possession is in the hands of a person who claims it for himself
until some time has elapsed or some condition has been fulfilled, but who acknowledges the title
of another for whom he holds the thing, and to whom he is prepared to deliver it when his own
temporary claim has come to an end: as for example when I lend a chattel to another for a fixed

10 Pollock and White , Possession In Common law Retrieved on 12 march ,, 2021. 17:24

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time, or deliver it as pledge to be returned on the payment of a debt. Even in such a case I retain
possession of thing so far as third persons are concerned.

Corporeal and Incorporeal Possession11:

Corporeal possession is the continuing exercise of a claim to exclusive use of a material thing.
The elements of this possession are just, the mental element of the claimant, the intent to possess,
to appropriate to oneself and second, the effective realization of this attitude. The effective
realization involves the exclusive control and enjoyment of thing at will without interference by
others. Actual use of it is not essential. It includes material things material things like land,
house, land, house, building etc. Incorporeal possession is connected with intangible things such
as trade mark, goodwill, right to vote, right to passage, etc. In vote, right to passage, etc. One can
acquire and retain possession o retain possession through actual and through actual and repeated
use repeated use of it. Incorporeal possession is commonly called the possession of a possession
of a right, and corporeal right, and corporeal possession is distinguished from it as the possession
of a thing.

Adverse and Constructive possession12: Adverse possession by a person holding the land on his
own behalf of some other person and setting up his claim as the true person and setting up his
claim as the true owner o owner of the land. diverse possession is continues,
peaceful ,undisturbed, and open for more than the year prescribed in different legal system then,
in India it is 12 years, the title of the true owner is extinguished and the person in possession
becomes the true owner.

The possession of master, landlord is constructive if things or land is not in their possession but
in the custody of the servant or tenant. It may be called as legal possession. Salmond said it
covers two cases, one that I discussed above, and another when one person has lost possession
and no one else has acquired it.

11 Dr. N. V. Paranjape, Studies in Jurisprudence and Legal Theory 413 (Central Law Agency, Allahabad, 8th edn.,
2016). Retrieved on 12 march ,, 2021. 17:23
12 Adverse Possession,: https://en.wikipedia.org/wiki/Adverse_possession. Retrieved on 12 march ,, 2021. 17:29

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Possession in Fact and Possession in Law 13: Possession in law is also known as dejure
possession. It exists when a person claims a thing as his own in a natural normal manner by
occupying a thing without any dispute as to his legal right to possess. Legal right may exist with
or without possession. It is just possible that a man may have ceased to live in a house but
without intending to abandon it for good as the owner of the house.

Possession in Fact is also known as defacto possession. It exists when the thing is in immediate
occupancy of a person. The person has physical control of the thing to the exclusion of others.
And has animus and corpus over the others. And has animus and corpus over the material object.
It is actual possession, It is actual possession, which can be held to be prima facie evidence of
ownership.

Of all the divergences between legal and actual possession what is most notable is that outside
the law possession is used in an absolute sense whereas within the law it is employed in a
relative sense. Outside the law we do not speak of a person having possession as against
someone else; we say that he against someone else; we say that he either has or either has or has

not got possession.

V. CONCEPT OF POSSESSION IN INDIA

The law of property under the ancient Hindu literature was most certainly not in light of any
guess yet was an exceedingly specialized and socialized institute. Its utilization and satisfaction
were confined and managed by the sacred texts. Holding of property by the individual was then
held to assist the general public in going ahead. The idea of possession14, therefore, under the old
Hindu Law was nothing.

However, a lawful contraption established in the contemplation of dharma. The possession that
was an exceedingly specialized institution in ancient India, was perceived by the Hindu Law
starting at two kinds to be specific,

13 Dr. Gokulesh Sharma, An introduction to Jurispruden Jurisprudence. Retrieved on 13 march ,, 2021. 17:12
14 V.D. Mahajan, Jurisprudence & Legal Theory 308 (Eastern Book Company, Lucknow, 5th edn., 1987). Retrieved
on 13 march ,, 2021. 17:12

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 • With title
• Without title

The possession without a title was expressed to have never made proprietorship and an individual
who was in possession of a thing or land without a title was considered as a hoodlum. At one
spot, Yajnavallkiya in his Smriti has pointed out that a man who sees his property being
delighted in by others and does not complain about it; he loses it following twenty years. If there
should be an occurrence of different properties proprietorship slips by following ten years by
unfriendly possession. Gautama and Narada to agreeing with the above have expressed that in
the land, an individual loses proprietorship following twenty years and in riches following ten
years.

Not just the ancient laws of Hindus. Muslim Law, as well, connected some significance to the
idea of possession. Sir Abdur Rahim commented that a man in possession, however by an
illegitimate possession, has under the Muslim Law focal points over the non-owner. The holder
is qualified for security against the whole world aside from the genuine proprietor. In India, the
Britishers who carried with them the jurisprudential idea of possession gave two components to
comprise possession, in particular,

• The corpus.
• The ill intention.

Yet, in India15, it is very much said that the theory and postulate with regards to possession
contain not just the privilege to have the right and capacity to prohibit others from possession
and control, also a mental component, the “animus possidendi“.

Both occupation and intention have essentially been viewed as critical to establishing possession.
In contrast to England, in India, it is further worth noting that there has been no such distinction
between custody and possession.

15 Supra note 3 at 430. Retrieved on 13 march ,, 2021. 17:23

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The unfriendly possession in India has been expressed to suggest possession by an individual
holding the immediate possession benefit of some individual other than the genuine proprietor
having a privilege of prompt possession. The possession obtained ought to be satisfactory in
certainty, inattention and in the degree to display that it is possession antagonistic to the
contender.

The quality and degree of the privilege obtained through antagonistic possession result rely on
the guarantee and nature of “hostility possidendi“. It is dependable “hostility” which must be
assembled from the conditions.

In, Bridges V. Hawkesworth16, the court ruled that the heap of notes found on the floor of a
shop go into the possession of the finder as opposed to the businessperson. The decision has been
bolstered by Pollock and Salmond. Pollock holds that since the retailer “defendant” has no
“corpus” in the heap of notes, he has no “de facto” power over it.

Salmond has taken this view, the business person has no “ill will” for possession. The decision
has, be that as it may be reprimanded by Prof. Goodhart and Granville Williams. In their opinion,
this case was wrongly decided on the grounds that the defendant businessperson had a general
“animus” and adequate control imperative for lawful possession of the notes was physically
found in the shop itself.

In, South Staffordshire water co. vs Sharman 17 the court ruled wherein, The defendant was
utilized by the organization, to get out a lake upon their property. He discovered certain gold
rings at the base of the lake while cleaning it. The court held that the organization had the
principal possession of the rings and not the defendant.

16 (1876) 1 ExD 285 (292) Retrieved on 13 march ,, 2021. 17:34

17 (1886) 33 Ch D 562. Retrieved on 13 march ,, 2021. 17:43

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 VI. CONCLUSION

Possession and proprietorship contrast in their modes of obtaining too. The exchange of
possession is nearly simpler and less specialized, yet the exchange of possession in most cases
involves a specialized procedure of convincing.

The privileges of possession18 and proprietorship are considered the equivalent. “Within the
points of confinement recommended by arrangement, the proprietor is permitted to practice his
normal control over the subject-matter interfered with, and is, pretty much, shielded in excluding
other individuals from such interference. The proprietor is permitted to exclude all and is
responsible to nobody. The owner is permitted to exclude everything except one and is
accountable to nobody but himself.

It can be safely concluded that possession is the most fundamental relation between a man and a
thing, but one of the most difficult concepts of the field of law. It is a very vast concept
consisting of various kinds and modes of acquisition which deal with the acquisition of res nullis
too. It is the prima facie evidence of ownership and is protected by law through various
possessory remedies like the statutory remedies are also available like section 5 and 6 of the
Specific Relief Act, 1963, section 145 of the Code of Criminal Procedure, 1973,section 47 and
48 of the Sale of Goods Act, as well as section 167 and 168 of the Indian Contract Act, 1872.
Also, for de jure possession both the elements of corpus and are necessary, as opposed to de
facto possession.

Possession exists in one who has physical control, weather rightful or wrongful, over a corporeal
thing. But it is not that there is no recognition of dejure possession in India.

18 Dr. Gokulesh Sharma, An introduction to Jurispruden Jurisprudence. Retrieved on 13 march ,, 2021. 17:48

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 VII . BIBLIOGRAPHY

1. Dias, Jurisprudence
2. Prof. S. N. Dhyani, Jurisprudence – a study of Indian legal a study of Indian legal theory
3. Salmond, Jurisprudence.
4. Dr. Gokulesh Sharma, An introduction to Jurispruden .
5. Dr. Harris, The concept of possession in English Law, Oxford Essays on Jurisprudence.
6. B.N. Mani Tripathi, Jurisprudence.

7. http://www.legalserviceindia.com/legal/article-1543-the-concept-of-possession-
itsmeaning-elements-kinds-and-modes-of-acquisition

8. https://www.legalbites.in
9. https://blog.ipleaders.in/theory-possession-jurisprudence/

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