SUBSTITUTION.

 

PARTITION LAW NO 21 OF1977

The law relating to the death of a party and the substitution of a legal representative in partition actions has undergone a profound and carefully structured evolution. When examined across the successive legislative regimes and judicial pronouncements, it reveals a clear movement away from procedural convention toward a statutory model grounded in finality and conclusiveness. The modern position cannot be appreciated unless one traces this development from its earliest doctrinal foundations through the statutory transformations and the judicial corrections that followed.

 

In the earliest phase, under the Partition Ordinance during the middle of the twentieth century, there existed no specialized statutory mechanism dealing with substitution in partition proceedings. The matter was governed by the general principles of civil procedure. The death of a party was treated as a serious procedural event which interrupted the continuity of the proceedings. Unless the legal representatives of the deceased were duly brought on record, the court could not validly proceed. This position rested upon the fundamental requirement that a court must have jurisdiction over the person against whom it proposes to adjudicate. A decree entered in the absence of a necessary party, or without proper representation, was liable to be treated as ineffective. In this period, substitution was not merely procedural but was tied to the very legitimacy of the adjudication.

 

The Partition Act No. 16 of 1951, although an important statutory development, did not fundamentally alter this position. While it introduced a more structured approach to partition litigation, it did not create a self-contained mechanism for dealing with the death of parties. The courts continued to rely upon general procedural principles. The requirement of substitution remained essential. The absence of substitution could still affect the validity of proceedings, and the law did not provide any express protection against such consequences.

 

The position remained largely unchanged under the Administration of Justice Law No. 25 of 1975. That enactment reorganized procedural law in several respects, but it did not introduce any significant innovation in relation to substitution in partition actions. The death of a party continued to attract the ordinary procedural consequences. The proceedings were regarded as defective if the legal representatives were not brought on record. The court could not proceed in ignorance of the death, and any adjudication made in such circumstances was vulnerable to challenge.

 

A more structured framework emerged with the enactment of the Partition Law No. 21 of 1977. This statute sought to codify and regularize the law relating to partition actions. Section 81, in its original form, empowered the court to appoint a person to represent the estate of a deceased party where such appointment was necessary or desirable to enable the court to proceed. However, this provision was discretionary in nature. It did not create an automatic mechanism for representation. Nor did it insulate proceedings from the consequences of non-substitution. It operated within a system that still assumed the necessity of proper representation as a condition of valid adjudication.

 

Section 81 of the Partition Law carried with it the following provision for substitution.

 

Representation of deceased party or co-owner.

81. Where a party to a partition action or any other person entitled, or claiming or alleged to be entitled, to any right, share, or interest to, of or in the land, dies after institution of that action, the court may, on the ex-pare application of any other party appoint a person to represent the estate of the deceased for the purposes of the action if the court is satisfied, after such inquiry as the court deems fit, that such appointment is necessary or desirable for the purpose of enabling the court to proceed with the action with a view to its speedy determination;

        

and any decree entered, order made, partition or sale effected, or thing done in the action shall, if the person so appointed is a party to the action, be for all purposes as valid and effectual as if the person lawfully entitled to the right, share or interest of the deceased were a party to the action,

 

 

This understanding of section 81 most clearly reflected in the original section 48(4)(a)(iii), which expressly contemplated the situation where a party died before judgment and no substitution had been effected or no representative had been appointed. It recognized that, in such circumstances, the rights of that party might be extinguished or prejudiced by the interlocutory decree. It therefore provided a remedy. The heirs or representatives of the deceased party could apply, within a specified time, for special leave to establish their rights notwithstanding the decree. This provision demonstrates that, under the law as it stood prior to the amendment No 21 of 1997, non-substitution was treated as a substantive defect capable of affecting rights and of undermining the integrity of the proceedings.

 

The judicial approach during this period was consistent with the statutory framework. Courts regarded the death of a party as interrupting the proceedings. The absence of substitution deprived the court of the necessary jurisdictional completeness. A decree entered in such circumstances could be set aside. Substitution was thus an essential procedural requirement, intimately connected with the validity of the adjudication.

                                   

The legislative policy underwent a decisive transformation with the enactment of the Partition (Amendment) Act No. 17 of 1997. This amendment fundamentally altered the legal framework. It introduced a comprehensive and forward looking system designed to ensure that partition proceedings would not be derailed by the death of parties. The amendment replaced the earlier discretionary mechanism with a structured regime centred upon nomination, automatic representation, and statutory validation.

 

Amendment of Section 81.

 

Section 81 of the Partition Law was repealed by Section 27 of partition (amendment) Law No 17 of 1997 and replaced with the following section renumbered as 81 containing 14 sub section each subsection systematically dealing with the procedure on the death of a party.

 

Section 81 as amended is produced below.

 

 

Replacement of section 81 of the principal enactment.

27. Section 81 of the principal enactment, is hereby repealed and the following section substituted therefor :-

Memorandum nominating legal representative.

81. (1) Every party to a partition action or any other person required to file a memorandum under this Law, (hereinafter referred to as "the nominator") shall file, or cause to be filed in court, a memorandum, substantially in the form set out in the Second Schedule to this Law, nominating at least one person, and not more than three persons, in order of preference, to be his legal representative for the purposes of the action in the event of his death pending the final determination of the action.

 

(2) (a) One of such nominees shall, in the order of preference in which their names are set out in the memorandum, be deemed to be the legal representative of the nominator for the purposes of the action, on the death of such nominator.

 

(b) In the event of the death or incapacity of any of the nominees whose names are set out in the memorandum, the person next nominated in order of preference shall be deemed to be the legal representative for the purposes of the action, in the event of the death of the nominator.

 

(c) The person or persons so nominated shall subscribe his or their signatures to the memorandum signifying consent to be so appointed as legal representative. The signatures of the nominator and those of the nominee or nominees so consenting to be appointed shall be witnessed by an Attorney-at-Law or Justice of the Peace or a Commissioner of Oaths:

 

Provided however, that failure to file such memorandum shall not by such failure alone render the plaint, statement of claim, or application to be added as a party defective or, notwithstanding anything in section 7, be a cause or ground for rejecting such plaint, statement of claim or any application to be added as a party.

 

(3) The court may at any time before the final determination of the action, on its awn motion or on the application of any party, require a party to the action or any person required to file a memorandum under the provisions of this Law, to file such memorandum on or before a date appointed for such purpose by court.

 

(4) A nominee may, at any time prior to the death of the nominator apply, with notice to the nominator, to court by way of motion to withdraw his consent to be such nominee and in such event the court shall make order that he ceases to be the nominee of the nominator and shall cause the name of such nominee to be struck off the memorandum filed by the nominator.

 

(5) A nominator may, subject to the provisions of subsection (1) of this section, at any time before the final determination of the action make application, with notice to the nominees, to tender a fresh memorandum nominating one or more nominees. On the filing of such new memorandum, the previous memorandum of such nominator shall stand revoked and the nomination contained in such fresh memorandum shall forthwith take effect.

 

(6) On the death of a nominator, the person first nominated in the memorandum filed by the nominator in order of preference, shall be deemed to be the legal representative of such nominator for the purposes of the action from the time of his death.

 

(7) A nominee deemed to be the legal representative of a deceased nominator shall be entitled to take all such steps for the purposes of the action as the deceased nominator would have been entitled to take had he been alive.

 

(8) (a) A nominee shall not decline to act as the legal representative of the deceased nominator. He may however with the leave of the Court first had and obtained, by way of petition and after notice to the other nominees if any, of such nominator, apply for permission from court to be released from the office of legal representative of such nominator.

 

(b) In the event of the court granting such permission, the nominee who is next in order of preference in the memorandum filed by the nominator shall be deemed to be the legal representative of such deceased nominator, for the purposes of the action.

 

(c) Where an application under paragraph (a) of this subsection is made by a nominee who was the sole nominee or sole remaining nominee of a deceased nominator, such nominee shall notice the heirs of such deceased nominator regarding his application and in the event of the court granting permission as aforesaid, such court shall appoint a consenting heir of such deceased nominator to act as the legal representative of such deceased nominator for the purposes of the action.

 

 

(9) Notwithstanding that a party or person has failed to file a memorandum under the provisions of this" section, and that there has been no appointment of a legal representative to represent the estate of such deceased party or person, any judgment or decree entered in the action or any order made, partition or sale effected or thing done in the action shall be deemed to be valid and effective and in conformity with the provisions of this Law and shall bind the legal heirs and representatives of such deceased party or person. Such failure to file a memorandum shall also not be a ground for invalidating the proceedings in such action.

 

(10) (a) On the death of a party or person who had failed to file a memorandum as required by this section, any party or person may apply to court by an exparte application, requesting that a person be appointed as the legal representative of such deceased party or person and the court may, on being satisfied after inquiry that such appointment is necessary, appoint a suitable person to be the legal representative of such deceased party or person for the purposes of the action. Such legal representative shall be bound by the proceedings had up to the time of such appointment.

 

(b) Such application and appointment shall not be a ground for the postponement of the trial or proceedings;

 

Provided that the court may, in its discretion, after recording reasons therefor and on the prepayment of costs, allow a postponement of the trial if in the opinion of court, it is in the interests of justice to do so

 

(c) In ordering pre-payment of costs the court shall take into account the date of institution of the action and the dates on which trial was held prior to such application and the stage at which the action is and any other matters which the court considers relevant.

 

 

(11) (a) An heir of a deceased nominator may, at any time after the death of such nominator, apply to court to have the legal representative of such deceased nominator removed and to have another person named in such application or the person next named in order of preference in the memorandum filed by the deceased nominator, appointed as such legal representative. The person who for the time being is the legal representative of the deceased nominator shall be made a respondent to such application.

 

(b) The court may, upon being satisfied that it is in the interests of the heirs of the deceased nominator to do so, remove such legal representative and appoint the person next named in order of preference in the memorandum filed by the deceased nominator or if there are sufficient grounds for doing so, appoint the person named in the application, as the legal representative of the deceased nominator.

 

(c) An application under this section shall he by way of petition and affidavit and the court may in its discretion, issue notice of the application to the other heirs, if any, of the deceased nominator,

 

 

(12) No proceeding under this Law shall be postponed or adjourned nor any step in the action postponed by reason of the death of a party or person required to file a memorandum under this Law.

 

(13) An application under subsections (4), (5),(8)(a), (10) or (11) shall not be aground for the postponement of the trial. The court may however grant a postponement on the payment of costs by the person making the application, if it is of the opinion mat it is in the interests of justice to allow such postponement.

 

(14) For the purposes of this section "legal representative" means, a person who represents me estate of a deceased party or person, for the purposes of the action, by virtue of a nomination, or of an appointment by court under this section.".

 

 

 

Procedural Rigidity to Statutory Finality in Partition Action.

 

Introduction: The Tension Between Procedure and Finality

 

The law relating to substitution and party representation in partition actions in Sri Lanka reveals a striking and deliberate evolution from rigid procedural orthodoxy to a pragmatic statutory regime designed to secure finality and stability of title. This development must be understood historically, for it is only through a careful tracing of its stages that one can appreciate the present legal position and the jurisprudential shift that underlies it.

 

In its essence, the evolution reflects a tension between two competing principles: procedural justice, which demands the presence of all necessary parties, and substantive finality, which insists that litigation must reach a conclusive end. The modern law represents a decisive preference for the latter.

 

The Ordinance Era: Substitution as a Condition of Jurisdiction

 

In the earliest phase, during the period governed by the Partition Ordinances of 1844 and 1863, there existed no special statutory framework addressing the consequences of the death of a party. Partition actions were governed by the general law of civil procedure, and the principles applied were strict and uncompromising.

 

The death of a party resulted in the abatement of proceedings unless proper substitution was effected. A court could not validly proceed in the absence of necessary parties, and any judgment entered against a deceased person was treated as a nullity. The requirement of substitution was not merely procedural but jurisdictional. A court could not bind a person who was not before it, and a dead person could not be represented in law.

 

Preservation of Procedural Orthodoxy under the Partition Act of 1951.

 

The Partition Act No. 16 of 1951, though introducing structural improvements, did not alter the procedural consequences of death. Substitution remained as a general procedural principle, and the absence of substitution continued to render proceedings defective.

 

Partition actions were still treated, in procedural terms, as ordinary civil actions, and the law continued to prioritize the proper constitution of parties over the completion of proceedings.

 

Continuity of the Classical Rule under The Administration of Justice Law No 25 of 1975.

 

The Administration of Justice Law reinforced the same procedural orthodoxy. The death of a party without substitution could result in abatement or invalidation of proceedings. The law remained firmly anchored in the traditional principle that no adjudication could be valid in the absence of all necessary parties.

 

The Emergence of Finality under the 1977 Partition Law and the Concept of Finality under Section 48.

 

The enactment of the Partition Law No. 21 of 1977 marked a turning point. Section 48 introduced a strong declaration that interlocutory and final decrees are final and conclusive for all purposes against all persons.

 

This provision elevated partition decrees into judgments operating in rem, binding not only the parties but the world at large.

 

5.2 Residual Procedural Vulnerability

 

However, this finality was not absolute. Section 48(4)(a)(iii) preserved the ability to challenge decrees on the ground of non-substitution. Thus, while the law recognized the need for finality, it still permitted procedural defects to undermine it.

 

The period between 1977 and 1997 may therefore be described as transitional.

 

Introduction of a Comprehensive Mechanism by Section 81 of Act No 21

The 1997 Amendment and the complete statutory transformation.

 

The Partition (Amendment) Act No. 17 of 1997 fundamentally altered the law. Section 81 was expanded into a comprehensive framework governing substitution and representation.

 

Each party was required to nominate a legal representative to act in the event of death. Upon death, the nominee automatically stepped into the proceedings, eliminating the need for formal substitution.

 

Automatic Continuity of Proceedings

 

This innovation ensured that proceedings would continue uninterrupted. The death of a party ceased to have procedural consequences capable of derailing the action.

 

Section 81(9): Statutory Validation Despite Non-Substitution

 

The most significant feature of the amendment is found in section 81(9). This provision declares that even where no nomination is made and no substitution takes place, all proceedings, judgments, decrees, and acts remain valid and binding on the heirs of the deceased party.

 

This represents a complete departure from earlier law. The failure to substitute, once fatal, is now rendered legally irrelevant.

 

Section 48 Revisited: Finality Reinforced and Protected

 

The amendment must be read alongside section 48. The repeal of section 48(4)(a)(iii) removed the earlier ground of challenge based on non-substitution. Section 48(1) continues to declare that decrees are final notwithstanding any procedural defect.

 

In the post-1997 context, non-substitution falls squarely within such defects and cannot affect the validity of the decree.

 

Judicial Conflict in the application of procedural provisions relating to substitution.

 

In Gamaralalage Karunawathie v. Godayalage Piyasena[1] the Supreme Court held that proceeding conducted without substitution was a nullity. The decision was based on general procedural principles and supported by Indian authorities. However, the judgment did not consider section 81(9), which had already altered the legal position.

 

The Doctrine of Per Incuriam and the Correction in Jane Nona

 

In Jane Nona and Others v. Surabiel and Others[2] the Court of Appeal corrected this position. It examined sections 48 and 81(9) and held that non-substitution does not invalidate partition proceedings.

 

The Court declared Gamaralalage Karunawathie v. Godayalage Piyasena to be per incuriam, applying the doctrine recognized in Young v. Bristol Aeroplane Co Ltd and Morelle Ltd v. Wakeling. A decision rendered in ignorance of a binding statutory provision lacks authority.

 

Final Resolution of the Supreme Court by a Divisional Bench.

 

The controversy was conclusively resolved in Bulathsinhala Arachchige Indrani Mallika v. Siriwardane[3], decided on 02.12.2022. A five-judge bench of the Supreme Court held that Karunawathie had been decided per incuriam in the context of partition law.

 

The Court affirmed that partition actions are governed by a special statutory regime and that statutory provisions prevail over general procedural principles.

 

Clarification in Modern Jurisprudence.

In Nimal Dhammika Jayaweera v. Margaret Lokubadusuriya and Others (2023) , the Supreme Court clarified the distinction between partition actions and ordinary civil actions.

 

In ordinary civil litigation, the death of a party without substitution results in abatement. In partition actions, however, the statutory scheme ensures continuity and validity despite such events. This distinction is now firmly established.

 

The Present Legal Position: A Statutory Regime of Continuity

 

The law may now be stated with clarity. In partition actions, the death of a party does not interrupt proceedings, and the failure to substitute does not invalidate the decree. The decree remains binding on all persons, including the heirs of the deceased.

 

The law has moved decisively away from procedural technicalities and now prioritizes finality and certainty of title. This evolution reflects a conscious legislative policy. Partition actions involve numerous parties and often extend over long periods. Death during litigation is inevitable. The law therefore ensures that proceedings continue and that decrees remain stable. The transformation, thus, represents a shift from procedural perfection to substantive stability.

 

15. Conclusion: Finality as the Governing Principle

 

It is therefore prudent (although he is not bound by law) for every District Judge hearing a partition action to satisfy himself, at the earliest possible stage of the proceedings, that each party has complied with the requirement of filing a memorandum nominating one or more persons to act as legal representatives in the event of death pending the final determination of the action. This requirement is not a mere administrative formality; it is a vital element of the statutory scheme, designed to ensure continuity of proceedings while at the same time safeguarding the interests of all parties concerned.

 

 

Footnotes

 

Gamaralalage Karunawathie v. Godayalage Piyasena (2011) 1 SLR 171.

Jane Nona and Others v. Surabiel and Others (2013) 1 SLR 346.

Bulathsinhala Arachchige Indrani Mallika v. Bulathsinhala Arachchige Siriwardane, SC Appeal No. 160/2016 (02.12.2022).

Nimal Dhammika Jayaweera v. Margaret Lokubadusuriya and Others, SC Appeal Nos. 45/2013 and 44/2013 (31.10.2023).

Young v. Bristol Aeroplane Co Ltd [1944] 2 All ER 293.

Morelle Ltd v. Wakeling [1955] 2 QB 379.

Mohammed Kamil Kuthubdeen v. Attorney General (Sri Lanka SC).

Subasinghe Mudiyanselage Rosalin Bertha v. Maththumagala Kankanamge Juwan Appu (Sri Lanka SC).

State of Punjab v. Nathu Ram AIR 1962 SC 89.

Swaran Singh v. Ramditta AIR 1969 P&H 216.

Kanailal Manna v. Bhabataran Santra AIR 1970 Cal 99.

Achhar Singh v. Ananti AIR 1971 P&H 477.



[1] (2011) 1 SLR 171,

[2]  (2013) 1 SLR 346,

[3] Sc Appeal No 160/2016

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