Lloyd's Maritime and Commercial Law Quarterly
FIRST COME, FIRST SERVED
Rishabh Raheja*
Bharat Sher Singh Kalsia v State of Bihar
In Bharat Sher Singh Kalsia v State of Bihar,1 the Supreme Court of India has affirmed an old principle of construction that, where two or more clauses of a contract cannot be reconciled, the earlier clause prevails over the later clause. This note argues that this decision is incompatible with the modern approach to interpretation of contracts.
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