CONTRACT LAW- II

DISSOLUTION OF PARTNERSHIP FIRM: THE

INDIAN PARTNERSHIP ACT, 1932

SUBMITTED BY
SNEHA
BALLB, 3RD YEAR

SUBMITTED TO
ASST. PROF. DR SINI JOHN

DATE- 25TH SEPTEMBER, 2020

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 CONTENTS
1. INTRODUCTION………………………………………………………………2

2. MEANING………………………………………………………………………3

3. MODES OF DISSOLUTION OF A PARTNERSHIP FIRM…………………..3

4. DISSOLUTION BY AGREEMENT……………………………………………4

5. COMPULSORY DISSOLUTION………………………………………………5

6. DISSOLUTION ON HAPPENING OF CERTAIN CONTINGENCIES ……...5

7. DISSOLUTION BY NOTICE OF PARTNERSHIP AT WILL………………...7

8. DISSOLUTION BY COURT……………………………………………………8

9. WHETHER RIGHT TO APPLY FOR DISSOLUTION CAN BE EXCLUDED..12

10. CONCLUSION………………………………………………………………….11

11. BIBLIOGRAPHY……………………………………………………………….13

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INTRODUCTION

The Indian law of partnership in India is based on the provisions of the English law of
partnership. Until the English Partnership Act of 1890 was passed, the law of partnership
even in England was largely based on legal decisions and custom. There were very few acts
of parliament relating directly to partnership. The Indian Partnership Act of 1932
(“Partnership Act”) was the result of a Report of a Special Committee.

The Indian Partnership Act enacted in the Year 1932 defining the law relating to partnership
the relation between the persons who have agreed to share the profits of a business carried on
by all or any of them acting for all -- makes it obligatory to have a partnership registered with
the Registrar of Firms, failing which the firm is prohibited from enforcing any right in a
Court of Law. This Act defines the relationship of partners to one another and to third parties
and lays down provisions as regards incoming and outgoing partners, dissolution of a firm,
etc. Under the Act partners are bound to carry on the business of the firm to the greatest
common advantage, to be just and faithful to each other and to render true accounts and full
information of all things effecting the firm to any partner or its legal representative. A partner
is liable to indemnify the firm for any loss caused to it by his willful neglect in the conduct of
the business of the firm. A partner is the agent of the firm for the purpose of the business of
the firm. The act also provides for the sale of goodwill of the firm after its dissolution and the
rights of the buyer and seller of the goodwill.

The dissolution of partnership between all the partners of a firm is called the dissolution of
the firm. (Section 39). As per Section 4, Partnership is the relation between persons who have
agreed to share profits of business carried on by all or any of them acting for all. Thus, if
some partner is changed/added/ goes out, the ‘relation’ between them changes and hence
‘partnership’ is dissolved, but the ‘firm’ continues. Hence, the change is termed as
‘reconstitution of firm’. However, complete breakage between relations of all partners is
termed as ‘dissolution of firm’. After such dissolution, the firm no more exists. Thus,
‘Dissolution of partnership’ is different from ‘dissolution of firm’. ‘Dissolution of
partnership’ is only reconstruction of firm, while ‘dissolution of firm’ means the firm no
more exists after dissolution.

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MEANING

A firm is not said to be dissolved by the fact of one or more members ceasing to be partners
in it while others remain, but only when all and every one of the members of the firm cease to
carry on its business in partnership. The law with respect to retiring partners as enacted in the
Partnership Act is to a certain extent a compromise between the strict doctrine of English
Common Law which refuses to see anything in the firm name but a collective name for
individuals carrying on business in partnership and the mercantile usage which recognizes the
firm as a distinct person or quasi corporation Matters pertaining not only to the fact of
dissolution and fixing the date thereof but also matters arising out of the fact of dissolution
which pertain to the winding up of the partnership, settlement of accounts, taking over of the
goodwill and assets of the partnership, restrictions on the outgoing partners carrying on
business in the case of transfer of goodwill to one of them, are all matters dealt with under the
subject ‘dissolution of a firm’.

A deed of dissolution must necessarily cover other matters, which arise directly out of
dissolution, such as settlement of accounts, payment of amounts found due on such
settlement, closing down or continuation of business collection of outstanding and payment
of liabilities. Notwithstanding such clauses in a deed of dissolution, it would be liable to
payment of stamp duty under art 47, Schedule I of the Bombay tamps Act 1958 and would
not be subject to separate duty on such matters. If a new firm is formed by agreement
between some of the former partners, it will nonetheless be new, however closely that
agreement may follow on the dissolution of the old firm. Whether a new firm is formed or not
is a question of fact.

MODES OF DISSOLUTION OF A PARTNERSHIP FIRM

A partnership firm can be dissolved by many modes like by agreement on the happening of
certain contingencies, or judicially. There are basically five modes of dissolution given under
Sections 40 – 44 of the Indian Partnership Act.

 Dissolution by Agreement – Section 40

 Dissolution by notice of partnership at will – Section 43

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  Compulsory Dissolution – Section 41

 Dissolution on the happening of certain contingencies – Section 42

 Dissolution by the Court – Section 44

The part VI of the Indian Partnership Act, 1932 from Section 39 to Section 55 which explains
the meaning of partnership and different modes through which the partnership firm can be
dissolved. Section 39: Dissolution of a firm The dissolution of partnership between all the
partners of a firm is called the ‘dissolution of the firm’. The Act recognizes the difference
between dissolution of a partnership firm and a mere retirement of a partner. On dissolution
each partner is paid his share of profits, if any, whereas on the retirement, death or
adjudication of one partner, a dissolution does not necessarily follow, for it may be a term in
the partnership agreement that a firm should be continued by other partners. The Supreme
Court in the case C.I.T , W.B vs. A.W Figgis & co. 1 clarified that “ there is no dissolution of
firm by mere incoming or outgoing of partners. A partner can retire and a person can be
introduced in partnership by consent of the other partners”.

Thus dissolution is something different from retirement of a partner, because in retirement of

a partner, the business is continued by one or more of the partners. Where immediately after
dissolution, the firm is reconstituted and the business resumed by the partners, even if in the
same name and place, that remains dissolution. 2 One out of four partners unilaterally
dissolved the firm and instructed the bank to freeze the account. He was holding minority
interest of 29%. The remaining partners with interest of 71% decided to continue the business
of the firm. As per the agreement the bank can be operated by any of the partners. It was held
that 29% holder could not have dissolved the firm unilaterally nor the bank could freeze the
account at his instance.

The Gujarat High Court3 also reiterated that in retirement a partner withdraws from the firm
without affecting the Jural relationship subsisting between other partners. There is no
severance of the jural relation with the partnership inter se between all the partners.

1
C.I.T , W.B vs. A.W Figgis & co. , A.I.R 1953
2
Best Enterprises vs. Elanchizian, AIR 2006 Mad 274
3
Keshavlal patel vs. Bhailal Patel, AIR 1968 Guj 157

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SECTION 40: DISSOLUTION BY AGREEMENT.

A firm may be dissolved with the consent of all the partners or in accordance with a contract
between the partners.

(1) By Contract: A firm may be dissolved at any time at the consent of all the partners. This
applies to all the cases whether the firm is for a fixed period or at will. A Dissolution was
held to have taken place in the case of a partnership at will when the partners decided not to
carry on the business of the firm from an agreed date.

(2) By Agreement: A firm may be dissolved in accordance with a contract between the
partners. The contract provided for dissolution may be contained in the partnership deed itself
or in a separate agreement. Both the above kinds of dissolution are provided in the same
section, but they are different. Partners can consent to dissolution regardless of what their
previous agreements are. But in dissolution by contract they have to follow their subsisting
agreement, whether all the partners give their consent or not. In the case law, Harish Kumar
vs. Bachan Lal4 , In the case, it was held that refusal and neglect on the part of any one
partner to perform the duties undertaken by him would give to any other partner the right to
apply for dissolution or without legal proceedings the partnership could by agreement be
dissolved.

SECTION 41: COMPULSORY DISSOLUTION. A FIRM IS DISSOLVED: -

Compulsory Dissolution: The two events mentioned in the section, namely, the insolvency
of all, or all but one , partners, or illegality of business are known as grounds of compulsory
dissolution because they operate to bring about such necessary dissolution that there can be
no agreement to the contrary. No amount of clauses in the act can prevent the operation of
Section 41. The 2 clauses mentioned in the Section are as follows:-

(a) Insolvency: The sub-Section is based upon the obvious principle that that there must
be at least 2 persons to constitute a firm. As already seen, on adjudication as insolvent
partner ceases to be a partner as from the date on which he is adjudicated an insolvent5
. Under Section 42(d), in the absence of a contract to the contrary the adjudication of a
single partner operates as a dissolution of a firm. The case contemplated, however by
this Section is where the whole firm adjudged insolvent, or all the partner but one are

4
Harish Kumar vs. Bachan Lal AIR 1991 P H 130, (1991) 99 PLR 188
5
Section 34

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 adjudged insolvent. It is clear that under circumstances, the firm is dissolved, there
being no question of a contract to the contrary.
(b) Prohibition of Business: where a partnership carrying a business in British/Indian
Territory is dissolved by 1 partner becoming an alien enemy and the Indian profits
made after the dissolution by the use of his capital, payment being of course
suspended during the war, an agreement may be void but not illegal. An agreement by
way of Wager is void but not illegal under Section 30 of the Contract Act. The
Supreme Court6 has held that a partnership formed for entering into wagering would
not be illegal; though it would be void. A firm, would not be illegal and its speculative
business being void would not be enforceable in the court of law. Where the business
of a firm is illegal from the very beginning, the agreement of partnership is itself
unlawful under Section 23 of the Contract Act.

SECTION 42: DISSOLUTION ON THE HAPPENING OF CERTAIN

CONTINGENCIES.

A firm is dissolved on the happening of any of the following contingences, provided

above, that there is no agreement to the contrary:

(a) If the firm is constituted for a fixed period, by the expiry of that firm: Where a
partnership has entered into for a fixed term, the partnership is at the end of the term
dissolved by the expiry of that term, without any further act or notice, even when
there is a partnership for a fixed period, the death of a partner taking place during the
continuance of the partnership period dissolves the partnership earlier6 .
(1) Expiry of a Term: where a firm is constituted for a fixed term, it becomes dissolved
on the expiry of that term, unless the dissolution is prevented by an agreement
between the partners. The Supreme Court held on the facts on the case before it that,
in the absence of an agreement to the contrary there was no question of the survival
of the firm after the expiry of the term of its term and the fact that the partners,
subsequent to the expiry of the term, consented to refer the disputes to arbitration did
not amount to an agreement to the contrary.9

(2) Completion of Business: A partnership is dissolved by operation of law when the

business for which it was formed has been completed. The Section says that when a firm
is constituted to carry out one or more adventures or undertakings, it is dissolved by the

6
Sayyed Abdul vs. Tumuluri, AIR 1927 Mad 491:(1927) 52 MLJ 318

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 completion thereof. Where, in a case before the Patna High Court, Ramnarayan vs.
Kashinath, the firm was working a salt license and control on salt being lifted, the firm
became inoperative, the question arose whether the firm had come into being only for
working the licenses or to carry on salt business whether, with or without control or
license, Ramswamy, the decision was, that the intention of the partners was that the
partnership should continue so long as the agency of salt continued or till separate
agencies were obtained.

(b) If the firm is constituted to carry out one or more adventures or undertakings, when
they are completed: This sub-section refers to the dissolution of particular partnerships 7.
Where a partnership was constituted only for the purpose of exploiting a salt license, the
partnership was dissolved on the salt control being lifted and on the termination of the
license8. So where a partnership was constituted to carry out contract with specified persons
during particular seasons and as the said contracts were closed, the partnership was dissolved.
However, the death of a partner dissolves earlier even a partnership for a particular
adventure9. Completion of an adventure or undertaking does not mean supply of or part or
even substantial part of the agreed goods. It is completed upon the realization of amount in
respect of the said supply.

(c) By the death of a partner10: The effect of clause (c) of Section 42 is that in the absence
of a contract to the contrary, a partnership is dissolved by the death of a partner. Death of a
partner means dissolution of partnership. In a case before the Rajasthan High Court 11 it was
contended against a firm that it should not be permitted to sue as one of the partners died and
the firm became dissolved; if the business was continued, it should be registered anew and
that not having been done it was not competent to sue.

(d) By the adjudication of a partner as an insolvent: A partnership is dissolved at the

adjudication of a partner as an insolvent. Where a partner in a firm is adjudicated an insolvent
he ceases to be a partner on the date on which the order of adjudication is made, whether or
not the firm is hereby dissolved. Where under a contract between the partners the firm is not
dissolved by the adjudication of a partner as an insolvent, the estate of a partner so

7
Section 8 (Definition of Particular Partnership)
8
Ramnarayan vs. Kashinath (1824), AIR 1954 Pat 53: (1953) 1 BLJR 289
9
Sayyed Abdul vs. Tumuluri, AIR 1927 Mad 491:(1927) 52 MLJ 318
10
If the firm remains in business after the death, it will be a new firm at any rate of the tax purposes. CIT vs.
Vinayaka Cinema, AIR 1978 AP 51
11
Kesrimal vs. Dalichand, AIR 1959 Raj 140.

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adjudicated is not liable for any act of the firm and the firm is not liable for any act of the
insolvent, done after the date on which the order of adjudication is made.

SECTION 43: DISSOLUTION BY NOTICE OF PARTNERSHIP AT WILL.

Dissolution of partnership at will.

Notice: - But in order to dissolve the firm the following conditions must be fulfilled:

A. Notice must be in writing;

B. Notice must express the intention of the partner to dissolve the firm; and

C. Written notice must be given to all the other partners.

Filing a suit in a court is not deemed to be a notice under Section 43(1). The Supreme Court
in Banarsi Das vs. Seth Kashiram held this .It was held that analogy of suits for partition of
joint Hindu family property with regard to which it is settled law that if all the parties are
majors, the institution of suit will result in the severance of the joint status of the family was
inapplicable under Section 43(1) because the rights of the partners of a firm to the property of
the firm are of a different character from those of members of a joint Hindu family. No
particular formality is required but the notice must be an unambiguous intimation of a final
intention to dissolve a partnership12. The notice must be explicit, precise and final.

13
In Devi Textiles vs. S. Suganthi there was a partnership at will and both the partners
(plaintiff and defendant) had 50% shares in the firm and both agreed to have the firm
dissolved and thereafter partners did not have good relationship, but the defendant continued
the business of the firm as if nothing happened and it is still in existence.

Decision: In such circumstances, it was held that the appointment of a receiver would be
proper for rendition of accounts and for completing winding up process.

SECTION 44: DISSOLUTION BY THE COURT

This declaration of the grounds for judicial dissolution corresponds, with verbal variation and
additional provision adapted to Indian procedure, to Section 35 of the English Act, which was
itself a somewhat enlarged version of Section 254 of the Contract Act. The Section confers a
right to pray for dissolution on any of the grounds specified therein notwithstanding any term

12
Parsons vs. Hayward, 1862
13
AIR 2000 Mad. 62, at p. 65.

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of the partnership deed. At the suit of a partner, the Court may dissolve the firm on the above
mentioned grounds.

(a) Insanity- Insanity does not dissolve the partnership ipso facto confirmed lunacy
provides a ground for dissolution by the court if other partners apply to court for
dissolution14. It is now clear that in the case of insanity, a next friend on behalf of the
lunatic may sue for dissolution. The judge exercising jurisdiction in lunacy is also
empowered to dissolve a partnership in the case of a partner becoming a lunatic (as
per Section 52 of Indian Lunacy Act, 1912). It is not necessary that the partner of
unsound mind should be found a lunatic by inquisition. The same was found in the
case of Jones vs. Lloyd, where dissolution was necessary to protect the interest of
insane and the other partners15 .
(b) Permanent Incapacity- whether any partner has become permanently incapable of
performing his duties as a partner; any partner can apply for dissolution. The
incapacity may be due to illness, mental or physical in nature but it must be
permanent. In the case law, Whitwell vs. Arthur16, a partner suffered from an attack of
paralysis and that would have been a good ground for dissolution for the fact that the
medical evidence showed that the attack was only temporary and he was already
improving.
(c) Partner guilty of conduct likely to affect prejudicially the carrying on of the
business. - At the suit of a partner, the court may dissolve a firm on the ground that a
partner, other than the partner suing, is guilty of conduct, which is likely to affect
prejudicially the carrying on of the business regard being had to the nature of the
business17.

TWO ASPECTS OF SECTION 44(C):

 The first thing to be noted in Section 44(c) is that if the partner filing the suit himself is
guilty of conduct which is likely to affect prejudicially the carrying on of the business, the
court will not order the dissolution of the firm.

As remarked in Harrison vs. Tenant18 , “No party is entitled to act improperly and then to say
that the conduct of the partners and their feelings towards each other are such that the
14
Jugal Chandra Bhattacharjee vs. Gunny Hajee Ahmed, 1925 53 Cal 214 at 225, 226 & 235, 91 IC
15
Rowland vs. Evans, 1824 43 Ch 826
16
Whitwell vs. Arthur 1865 beva 140.
17
3 Section 44(c), The Indian Partnership Act, 1932
18
[1856] ALL ER 945

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partnership can no longer be continued and certainly this court would not allow any person so
as to act and thus to take advantage of his own wrong.

 The second important thing to be noted in Section 44 (c) is that in order to dissolve the
firm on this ground, it is necessary that the partner must be guilty of a conduct which keeping
in view the nature of the business is likely to affect prejudicially the carrying on of the
business. If the partner is guilty of wrongful act willfully, the mere fact that his continuance
in the partnership firm will be detrimental for the firm will not be sufficient to dissolve the
firm. It may also be noted that much depends on the nature of the business.

In Snow vs. Milford19, a partnership firm carried on the business of the bankers.

(d) Persistent Breach of Agreement- When a partner, other than suing persistently
commits breach of agreement relating to the management of the firm or otherwise so
conducts himself in matters relating to business that it is not reasonably practicable
for the other partners to carry on the business in partnership with him, the court may
order dissolution. The court may order for the dissolution of the firm if the partner
other than the suing partner is found guilty for constant breach of agreement regarding
the conduct of business or the management of the affairs of the firm and it becomes
impossible to continue the business with such partner.
(e) ) Transfer of Interest – When a partner has transferred the whole of his interest in
the firm, to a third party or has allowed his interest to be charged, or has allowed it to
be sold in, the recovery of arrears of land revenue, or any of the dues recoverable for
land revenue, the court may order dissolution. When any of the partner other than the
suing partner transfers whole of its share to the third party for permanently.
(f) Perpetual Losses – When the business of the firm cannot be carried on save at a loss,
the court may dissolve it. The whole object of the Partnership is to make profits and if
that object cannot be attained, it is needless for the firm to continue. Thus where
whole of the capital contributed by the partners had already been spent and there were
no business prospects unless they contributed further capital which they refused to do,
the court granted dissolution20
(g) Just & Equitable – Dissolution may be ordered when on any other ground the court
thinks it just & equitable that the firm should be dissolved. The expression, “just and

19
(1868) 18 LT 142
20
Jeening vs. Baddeley, 1856 3 K&J 78

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 equitable” gives the court a very wide discretionary power, which is not fettered by
any rules, to order dissolution whenever in the circumstances it seems desirable21.

Whenever a case is brought to the case under Section 44(g), the court has to decide whether it
would be ‘just and equitable’, to dissolve the firm and such matters cannot be left for decision
or award of the arbitration 22 . Under Section 44(f), 6the court has to decide according to its
discretion but this discretion cannot be restricted by rigid or inflexible rules. The court has to
use its discretion on the basis of facts and circumstances of the case.

For example, in one case 4 out of 9 partners wanted dissolution of the firm and their shares
in the firm was 7/9. There was no cooperation and mutual faith between the partners. There
were many and long-persisting disputes among them.

The court held that it would be just and equitable to dissolve the firm. The court may order
for dissolution on any other ground which court think is just, fair and equitable. E.g. loss of
total confidence between the partners was held in case of Havidatt Singh vs. Mukhe Singh.

WHETHER RIGHT TO APPLY FOR DISSOLUTION CAN BE EXCLUDED

The right of a partner to ask for dissolution on any of the above grounds cannot be excluded
by nay agreement to the contrary23. Where the no other mode of dissolution is available,
Section 44 being the lender of last resort, its operation cannot be allowed to be nullified. The
Allahabad High Court has, however, held differently. In a case before it the partnership deed
provided that a partner could withdraw it by selling his interests to his co-partners or, in the
event of their failure to buy it, by selling it to the others and dissolving the firm. The other
partner failed to buy and, therefore, dissolution was prayed for, but was not granted, the court
saying that the provision had taken away a partner’s right to cause dissolution. This view is,
however, now no longer tenable. Following a Privy Council Decision 24 the J&K High Court
stated that “It can be safely said that Section 44 confers an absolute and independent right and
it is not open to the partner’s to take away that right by means of an agreement between them.

21
4 N. Satyanarayana vs. M. Vekanta Bala, 1989 AIR AP 167, 175
22
Nainder Singh Randhava vs. Hasrdial Singh Dhillon, AIR 1985 P&H 41; See also Kalpana Kothari vs. Sudha
Yadav, (2002) 1 SCC 203; AIR 2002 SC 89.
23
Hardutt Singh vs. Mukha Singh, AIR 1973 J&K 46
24
Vishnu Chandra vs. Chandrika Prasaad, 1983

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STAY OF ARBITRATION

Although the arbitration clause in a partnership agreement may be sufficiently wide to

include the question whether the partnership should be dissolved, the court in its discretion
may not stay a suit for dissolution, if dissolution is sought under Section 44(g). Whenever
dissolution of partnership is sought under Section 44(g), then it is for the court to decide,
whether it would be just and equitable to dissolve the partnership or not and such a matter
cannot be left to be gone into and decided by the arbitrator in pursuance of the arbitration
clause contained in the partnership deed. Last but not least, it may be noted that Section 44 is
not subject to contract between partners. It confers right on the partners to file suit for the
dissolution of the firm on the ground mentioned in the Section.

CONCLUSION

We can conclude that the firm is dissolved when all the partners stop carrying on the
partnership business. If some partners dissociate from the firm and the remaining partners
continue the business of the firm, the firm is not dissolved.

The dissolution of a firm is distinct from the retirement of a partner because in latter situation
others or remaining partners continue the business of the firm and the firm is not dissolved.
Thus dissolution of partnership between all the partners of a firm is called dissolution of the
firm. The dissolution of the partnership brings about a change in the relations between
partners but partnership between them does not completely end. The partnership continues
for the purpose of realization of assets or properties of the firm. Further, after the dissolution
of a firm the authority of each partner to bind the firm, and the other mutual rights and
obligations of the partners, continue notwithstanding the dissolution, so far as may be
necessary to wind up the affairs of the firm and to complete transactions begun but unfinished
at the time of the dissolution, but not otherwise.

BIBLIOGRAPHY

PRIMARY SOURCES

Books

 Introduction of Law of Partnership- Avtar Singh, Eastern Book Company (10th Edition,
2011)

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 The Sale of Goods Act & The Indian Partnership Act, Sir Dinshah Fardunji Mulla (10th
Edition 2012) Internet Articles

http://admis.hp.nic.in/himpol/Citizen/LawLib/C142.htm#s39

http://www.slideshare.net/AdityaKumar33/presentation1-16292027

http://www.legislation.gov.uk/ukpga/Vict/53-54/39/contents

http://www.lawweb.in/2013/01/settlement-of-accounts-between-partners.html

http://legal360.in/SearchDetail?topic=74667

https://books.google.co.in/books?id=8ZE0AAAAIAAJ&pg=PR23&lpg=PR23&dq=rowl
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 http://www.lawnotes.in/Section_48_of_Indian_Partnership_Act,_1932

SECONDARY SOURCES

Articles

 The Economic Consequences of Partnership Dissolution—A Comparative Analysis of

Panel Studies from Belgium, Germany, Great Britain, Italy, and Sweden
http://esr.oxfordjournals.org/content/22/5/533.shor

 The effects of Partner and Relationship Characteristics on Alliance Outcomes

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