DR.

RAM MANOHAR LOHIYA NATIONAL LAW UNIVERSITY,

LUCKNOW

RESEARCH

PROJECT

RULE OF

SUBROGATION

SUBMITTED TO: DR. RADHEYSHYAM PRASAD, ASSISTANT PROFESSOR (LAW), AS PART OF

THE WRITTEN ASSIGNMENT (PROJECT WORK) FOR PROPERTY LAW II.
SUBMITTED BY: NAZIM ASHRAF (ROLL NO. - 76), B.A. LL.B. (HONS.) SEM. VI 2015-16

ACKNOWLEDGEMENT

Though this research project initially came up as just one submission for the end of the semester,
I am very happy to submit that a substantial amount of research has gone into the making of the
same. Here I should acknowledge Dr. Radheyshyam Prasad, Assistant Professor of Law at Dr.
Ram Manohar Lohiya National Law University, Lucknow without whose guidance this research
project wouldnt have been possible. I would also like to thank Dr. Madhu Limaye Library, Dr.
Ram Manohar Lohiya National Law University, Lucknow which provided me with the required
support both in the form of books and online database which has been of immense value to this
project. In the course of this project, I have also reproduced various parts of published and non
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published researches which have been duly cited. I would also like to thank the authors of the
same.

Nazim Ashraf
Lucknow, March, 2016.

CONTENTS

INTRODUCTION.........................................................................................................................4

HISTORICAL PERSPECTIVE...................................................................................................5

KINDS OF SUBROGATION........................................................................................................8

CASE LAWS..................................................................................................................................9

SUBROGATION AND ALLIED PRINCIPLES.......................................................................14

BIBLIOGRAPHY........................................................................................................................17

INTRODUCTION
The Doctrine of subrogation in the Transfer of Property Act, 1882, has been laid down under
section 92, inserted after an amendment in the year 1929.
The plain text of the section is as under:
Subrogation: Any of the persons referred to in section 91 (other than the mortgagor) and any comortgagor shall, on redeeming property subject to the mortgage, have, so far as regards
redemption, foreclosure or sale of such property, the same rights as the mortgagee whose
mortgage he redeems may have against the mortgagor or any other mortgagee.
The right conferred by this section is called the right of subrogation, and a person acquiring the
same is said to be subrogated to the rights of the mortgagee whose mortgage he redeems. A
person who has advanced to mortgagor money with which the mortgage has been redeemed shall
be subrogated to the rights of the mortgagee whose mortgage has been redeemed, if the
mortgagor has by a registered instrument agreed that such persons shall be so subrogated.
Nothing in this section shall be deemed to confer a right of subrogation on any person unless the
mortgage in respect of which the right is claimed has been redeemed in full.
From the above we can conclude that section 92 provides for:
I. any person other than the mortgagor referred to in section 91, and any co-mortgagor,
II. on redeeming the mortgaged-property,
III. shall have the same rights as the mortgagee whose mortgage he redeems may have against
the mortgagor or any other mortgagee,
IV. the rights are regarding redemption, foreclosure or sale of the mortgaged property.
V. This right is known as the right of subrogation and the person acquiring the same is said to be
subrogated to the rights of the mortgagee whose mortgage he redeems.
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As defined under the Black's Law dictionary, 'Subrogation' is: the substitution of one person in
the place of another with reference to a lawful claim, demand or right, so that he who is
substituted succeeds to the rights of the other in relation to the debt or claim, and its rights,
remedies, or securities.

HISTORICAL PERSPECTIVE
Subrogation is a roman term, which means 'substitution'. Lord Hardwicke in his decision in
Randal V. Cockran marked its identification with equity, in his opinion expressed, he suggested a
possible theoretical basis for the doctrine and a justification for the role of equity in the area of
contribution. In a letter to Lord Kames, he had noted that new commercial conditions, new
methods of dealing with property, and different forms of property made it necessary for equity to
play a novel part in the further development of subrogation.
The above case arose out of a decree by King George II allowing compensation to be paid to
those that suffered loses in a war with Spain. Some individuals had already been indemnified by
their insurers for the losses that they had suffered, and the insurers successfully sought to be
subrogated to the rights of their insured to receive this compensation.
The first English case to adopt the word 'subrogation' was Stringer V. The English and Scotch
Marine Insurance Co. In this case, the plaintiffs insured a ship cargo with the defendants for
'taking at sea, arrests, restraints, and detainment of all Kings, princes and people.' The ship was
subsequently captured by a United States cruiser and taken into New Orleans, where a suit for its
condemnation was instituted. The plaintiffs contested the action successfully and the captors
appealed. The court ordered the plaintiffs to furnish security against costs, which they could not
afford. As a result, the ship was condemned; the plaintiffs gave formal notice of abandonment of
the cargo, and requested the insurers pay for their total loss. The court, in holding for the
plaintiff, noted that the plaintiff as the assured was free to choose between defending the appeal
before the American court or claiming a loss under the policy. Because the assured chose the
latter, the insurers were obligated to pay. However, having paid, the insurers were entitled 'to be

subrogated to them, and get what they can out of the hands of the Americans for their own
benefit.'
Though, there has been some disagreement in English courts about whether subrogation is an
equitable or legal doctrine. Canadian courts have treated it as the former. The leading case in
Canada is National Fire Insurance Co. V. McLaren which states:
The doctrine of subrogation is a creature of equity not founded on contract, but arising out of the
relations of the parties. In cases of insurance where a third party is liable to make good the loss,
the right of subrogation depends upon and is regulated by the broad underlying principle of
securing full indemnity to the insured on the one hand, and on the other of holding him
accountable as trustee for any advantage he may obtain over and above compensation for his
loss. Being an equitable right, it partakes of all the ordinary incidents of such rights, one of
which is that in administering relief the Court will regard not so much the form as the substance
of the transaction. The primary consideration is to see that the insured gets full compensation for
the property destroyed and the expenses incurred in making good his loss. The next thing is to
see that he holds any surplus for the benefit of the insurance company.
Whether the doctrine is equitable or not, the Canadian and English jurisprudence is agreed that
subrogated rights do not come from the contract of indemnity but arise by operation of the
common law to govern the relationship that such a contract creates.
At common law, no subrogated rights arise until the insured is fully indemnified for its loss.
Once full indemnity is made, the insurer has the right to commence proceedings against the
wrongdoer in the insured's name and make all decisions in the litigation. The insured has a duty
to co-operate in the litigation in matters such as giving evidence at trial.
It was in the case of London Assurance Co. V. Sainsbury the principles of subrogation
established by equity were taken and forged into the common law. However, the common law
also assumed a major role in fashioning the future progress of the purely equitable doctrine. The
Court of Exchequer in the case of Deering v. Winchelsea, held that The basis of 'bottom of
contribution' was said to be a fixed principle of Justice, and is not founded in Contract:

[t]his contribution is considered as founded in Equity; Contract is not mentioned. The principle
operates more clearly in a Court of Equity than at Law. At Law the party is driven to an Audita
Querela or Seire Facias to defeat the execution, and compel execution to be taken against all.
In Craythorn V. Swinburn , the court explained the grounds upon which the courts of law could
justify the application of equitable rules in the field of contribution:
It has been long settled that, if there are co-sureties by the same instrument, and the creditor calls
upon either of them to pay the principal debt, or any part of it, that surety has a right in this
Court, either upon a principle of Equity, or upon Contract, to call upon his co-surety for
contribution; and I think, that right is properly enough stated as depending rather upon a
principle of Equity than upon Contract: unless in this sense; that, the principle of Equity being in
its operation established, a Contract may be inferred upon the implied knowledge of that
principle by all persons, and it must be upon such a ground of implied assumption, that in
modern times Courts of Law have assumed a jurisdiction upon this subject.
The Privy Council in the case of Gokuldas V. Puranmal held that Gokuldas was subrogated to the
rights of the prior mortgagee whom he had paid off and that this claim could not be disposed
unless it was redeemed. As per the facts of the case Gokuldas, was the creditor of the mortgagor,
purchased the equity of redemption at a sale in execution of a money decree and got possession.
He paid off a prior mortgagee but was sued for possession by a puisne mortgagee. Further the
council through this decision declared the inapplicability of the rule in Toulmin V. Steere in
India, according to the principle laid down by this case when a purchaser of equity of redemption
is redeeming a mortgage there is no presumption that he intend to keep it alive against
subsequent encumbrance of which he has no knowledge but may have had constructive notice.
As recognized by the American courts, the one who initially discharges the obligation is called
the 'subrogee' and the party who is compensated is the called 'subrogor.'

KINDS OF SUBROGATION

1. Legal Subrogation
This kind of subrogation takes place by operation of Law, and is based on the principle of
reimbursement. Where a person is interested in making some payment, which another is legally
bound to make, than such person must be reimbursed when he makes the payment. Legal or
equitable subrogation is not available to volunteers, and is not available until full compensation
has been paid. It is based on equitable considerations.
The following people can claim Legal Subrogation :
a) Puisne mortgagee
He is a subsequent mortgagee, who redeems a prior mortgage; he has a right to be subrogated to
the position of the prior mortgage.
b) Co-mortgagor
He is liable only to the extent of his share of the debt. When, besides redeeming his own share,
he pays off the share of the other mortgagor also, he becomes entitled to be subrogated in place
of such other mortgagor. In the case of Krishna Pillai Rajasekharan V. Padmanabha Pillai the
question arose whether arose that what were the rights and liabilities the parties qua each other
and whether a suit for the partition was maintainable. The court here held that it was not a case of
subrogation by agreement but by the operation of law. Section 92 does not have the effect of a
substitute becoming a mortgagee. The provision confers certain rights on the redeeming comortgagor and also provides for remedies of redemption, foreclosure and sale being available to
the substitutes as they were available to the substituted. Therefore, the suit for declaration,
partition and recovery of possession by non- redeeming co-mortgagor was held to be
maintainable.

c) Surety
The person, who stands as a surety in a mortgage for repayment of loan in case mortgagor fails
to do so, is also entitled to redeem the mortgaged property under section 91. When the surety of
the mortgagor redeems the property he is subrogated to the position and rights of the creditor.
d) Purchaser of equity of redemption
There were certain doubts regarding the purchaser of equity of redemption that whether he can
be subrogated or not. Equity of redemption is regarded as a property of the mortgagor, which he
can sell or assign. The purchaser of such equity becomes owner of the property. The Privy
Council in the case of Malireddy Ayyareddy V. Gopi Krishnayya held
'it is now settled law that where in India there are several mortgages on q property, the owner of
the property subject to a mortgage may, if he pays off an earlier charge, treat himself as buying it
and stand in the same position as his vendor, or to put it in another way, he may keep the
encumbrance alive for his benefit and thus come in before a later mortgagee. This rule would not
apply if the owner of the property had covenanted to pay the later mortgage- debt but in this case
there was no such personal covenant.'

2. Conventional Subrogation
The conventional Subrogation takes place where the person paying off the mortgage- debt is a
stranger and has no interest to protect, but he advances the under an agreement, that he would be
subrogated to the rights and remedies of the mortgagee who is paid off. The right to subrogation
can be claimed only if the mortgagor has agreed by registered instrument that he shall be
subrogated.

CASE LAWS

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The question before the court in the case of Isap Bapuji Amiji' V. Umarji Abhram Adam , was
whether, Section 92 of the Transfer of Property Act, 1882, has retrospective effect or not; as per
Broomfield, J., the retrospective effect should be taken as a guide for determining in cases, where
there is a conflict of authority, what equitable rules not inconsistent with the Act should be
adopted as valid in India; whereas according to N.J. Wadia, J., Section 92 of the Transfer of
Property Act, as amended in 1929, has a retrospective effect.
It was held in the case of Narain V. Narain , that where the mortgagor himself redeems the
property this doctrine couldn't be invoked. The mortgagor who discharges a prior debt is not
entitled to be subrogated to the rights and remedies of his creditor. This is because by discharging
a prior encumbrance created by himself, he is discharging his own obligation to his creditor.
In the case of Vishnu Balkrishna Naik V. Shankareppa Gurlingappa Wagarali , the Bombay High
Court has opined that:
Where a person himself redeems a mortgage, that is to say, pays the mortgage money out of his
own pocket and not merely discharges a contractual liability to make the payment, he is entitled
to the right of subrogation under the first paragraph of Section 92, if he is one of the persons,
other than the mortgagor, enumerated in Section 91. Where, however, such person does not
himself redeem the mortgage, that is to say, does not himself pay the money out of his own
pocket in excess of his contractual liability but advances money to a mortgagor and the money is
utilized for payment of a prior mortgage, whether the money is actually paid through the hands
of the mortgagor or is left for such payment in the hands of the person advancing the money and
it is then paid to the prior mortgagee through the hands of that person, the latter acquires the right
of subrogation under the third paragraph of Section 92, only if the mortgagor has by a registered
instrument agreed that he shall be so subrogated.
The Supreme Court in the case of Ganesh Lal V. Joti Prasad discussed the nature and extent of a
redeeming co-mortgagors right to recover contribution from his co-debtor, The court here held
that,
Equity insists on the ultimate payment of a debt by one who in justice and good conscience is
bound to pay it, and it is well recognized that where there are several joint debtors, the person
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making the payment is the principal debtor as regards the part of the liability, he is discharged
and a surety in respect of the shares of the rest of the debtors. Such being the legal position as
among the co-mortgagors, if one of them redeems a mortgage over the property which belongs
jointly to himself and the rest, equity confers on him a right to reimburse himself for the amount
spent in excess by him in the matter of redemption; he can call upon the co-mortgagors to
contribute towards the excess which he has paid over his own share... while it can be readily
conceded that the joint debtor who plays up and discharges the mortgage stands in the shoes of
the mortgagee... he will be subrogated to the rights of the mortgage only to the extent necessary
for his own equitable protection... so far as it is necessary to enforce his equity of
reimbursement'.... It is as regards the excess of the payment over Ms own share that the right can
be said to' exist.... The redeeming co-mortgagor being only a surety for the other co-mortgagors,
his right, strictly speaking is a right of reimbursement or contribution.
The above mentioned judgment has been upheld time and again by the Supreme Court itself and
various High courts.
The same view was upheld by the Supreme Court in the case of Valliamma Champaka Pillai V.
Sivathanu Pillai and Ors. , where it was held that the rights created in favor of a redeeming comortgagor as a result of discharge of debt are 'so far as regards redemption, foreclosure or sale of
such property, the same rights as the mortgagee whose mortgage he redeems'. Further
Subrogation rests upon the doctrine of equity and the principles of natural justice and not on the
privity of contract, One of the principles is that a person, paying money which another is bound
by law to pay, is entitled to be reimbursed by the other. This principle is enacted in Section 69 of
the Contract Act, 1872. Another principle is found in equity: he who seeks equity must do equity'
The High Court of Kerala in the case of Sivasankara Pillai & Anr.V. Narayana Pillai & Ors. Has
drawn a distinction between section 92 of the TP Act and section 69 of the Indian Contract Act,
1872 on the basis of the fact that, Subrogation rests upon the doctrine of equity and principles of
natural justice and not on privity of contract S. 92 of the Transfer of Property Act and S. 69 of the
Contract Act recognises the principle of equity of reimbursement.

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When the scope section 92 of the Transfer of Property act and the extent of rights and powers of
subrogee, came into consideration before the court in the case of Krishna Pillai Rajasekharan
Nair V. Padmanabha Pillai , the court summarized the principles laid down in the case of Ganeshi
Lal as under:
Having examined the issue from all-possible angles and having referred to Sir Rashbehary Ghose
on Law of Mortgage in India, Harris on Subrogation, Sheldon on Subrogation, Pomeroy on
Equity Jurisprudence and a few English and Indian authorities available on the point, what Their
Lordships conclusion in Ganeshi Lal case may be summed up as under:
1. When the co-debtor or co-mortgagor pays more than his share to the creditor for the purpose
of redeeming a mortgage, the redeeming mortgagor is principal debtor to the extent of his share
of the debt and a surety to the extent of the share in the debt of other co-mortgagors. The
redeeming co-mortgagor being only a surety for the other co-mortgagors, his right is, strictly
speaking, a right of reimbursement or contribution.
2. The substitution of the redeeming co-mortgagor in place of the mortgagee does not precisely
place the new creditor (i.e. the redeeming co-mortgagor) in place of the original mortgagee for
all purposes. If, therefore, one of the several mortgagors satisfies the entire mortgage debt,
though upon redemption he is subrogated to the rights and remedies of the creditor, the principle
has to be so administered as to attain the ends of substantial justice regardless of form; in other
words, the fictitious cession in favor of the person who effects the redemption, operates only to
the extent to which it is necessary to apply it for his indemnity and protection.
3. The doctrine of subrogation must be applied along with other rules of equity so that the person
who discharges the mortgage is amply protected and at the same time there is no injustice done
to the other joint debtors. He who seeks equity must do equity.
4. There is a distinction between a third party who claims subrogation and a co-mortgagor who
claims the right. The co-mortgagors stand in a fiduciary relationship qua each other. The
redeeming co-mortgagor can only claim the price, which he has actually paid together with
incidental expenses. Strictly speaking, therefore, when one of several mortgagors redeems a
mortgage, he is entitled to be treated as an assignee on the security, which he may enforce in the
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usual way for the purpose of reimbursing himself. The subrogation to the rights of the mortgagee
by the redeeming co-mortgagor is confined only to the extent necessary for his own equitable
protection. The redeeming co-mortgagor can, just as the surety would, ask to indemnify for his
loss and he can invoke the doctrine of subrogation as an aid to the right of contribution.
Further in the case of Oriental Fire & General Insurance Co. Ltd.V. American President Lines
Ltd. and Anr. , Maharashtra High Court drew an distinction between section 92 and section 135A
of the act:
The difference between subrogation under Section 92 of the Transfer of Property Act, 1882, and
Section 135A of the Act is that under Section 92 the subrogation results in the extinction of the
original mortgagee's rights and, therefore, the original mortgagee has no more rights under the
mortgage, whereas a subrogee under Section 135A acquires rights only to the extent of his
payment which may be less than the rights of the assured himself. Another distinction is that the
person who redeems under Section 91 is an interested person or a surety or a creditor and under
that section that subrogee would get the rights conferred under Section 69 of the Indian Contract
Act, 1872, because it would be a payment made by a person interested; but in the case of
subrogation under Section 185A the insurer pays under his own contract of insurance and he is
not interested in discharging the liability of the wrongdoer or the tortfeasor. The third distinction
is that Section 92 confers on the person redeeming rights of the mortgagee 'against the mortgagor
or any other person'. It is these words that confer the right to sue. There are no such words in
Section 135A(2) and (3) as 'against the wrongdoer or tortfeasor.'
In the case of Velayudhan Padmanabhan'V.' K. Thyagarajan, the court held that, as under section
92 of the act:
A co-mortgagor is entitled to file a suit for redemption of mortgage. A co-mortgagor who
redeems the mortgage would have the same rights as the mortgagee whose mortgage he redeems
may have against the mortgagor, in so far as regards redemption, foreclosure or sale of the
property, as per Section 92 of the Transfer of Property Act. Such redeeming co-mortgagor gets
subrogated to the rights of the mortgagee whose mortgage he redeems. The redemption sought
for in the present case is in respect of the whole of the mortgaged property and not the one-half
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share of the plaintiff. The bar contained in Section 92 of the Transfer of Property Act is that a
right of subrogation would not be available to any person unless the mortgage in respect of
which the right is claimed has been redeemed in full.
In the case of Maheswaradhathan Nambudiri V. Narayanan Nambudiri and others, Kerala High
Court has further held that:
When a mortgagor redeems a mortgage what happens is the extinction of the mortgage right by
its satisfaction, and the question of redemption partaking the nature of an assignment, thus
keeping the mortgage right alive, can arise only in cases where the redemption gives the person
redeeming the right of subrogation to the rights of the mortgagee whose mortgage he redeems
Section 92 makes it clear that the mortgagor has no such right and it is clear that when a
mortgagor redeems a mortgage the mortgage is extinguished and is in no sense kept alive even if
there be some intervening interest like a puisne mortgage.
In the case of Thamattoor Chelamanna and Anr.V. Thamattoor Kurumbikkat Pare Manakkal
Parameswaran and Ors. the question that arose before the Kerala High Court was, whether
person redeeming has right of subrogation in respect of redeemed sub-mortgage, The court here
held that, where person redeeming is a mortgagor no such right of subrogation arises, further,
there is no question of mortgagor holding redeemed sub-mortgage as separate right.
Additionally, in the case of Raghavendracharya Appacharya Katti V. Vaman Shriniwas
Deshpande the Bombay High court drew analogy between subrogation and substitution, as
under:
Subrogation means neither more nor less than substitution. A person who is subrogated to the
status of a mortgagee has all the rights of a mortgagee, not merely some of the rights, and those
rights must include rights in connection with the particular mortgage by redeeming which he gets
the benefit of Section 92 of the Transfer of Property Act. One of the implications of the doctrine
of subrogation is that the subrogee keeps the mortgage alive for his own benefit. The mortgage
that is paid off is not extinguished but is treated as assigned to the subrogee.

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SUBROGATION AND ALLIED PRINCIPLES

Subrogation and Assignment

It was held in the case of Gujrath Andhra Road Carriers Transport Contractors V. United India
Insurance Co. Ltd., an assignment or transfer can take place only with specific acts of parties.
The assignee or transferee acquires all the rights in the property. A transfer operates as a transfer
of the totality of the rights. Similar principle has been laid down by the American courts in the
case of Western Cas. & Sur. Co. V. Bowling and Hospital Serv. Corp.V. Pennsylvania Ins. Co.
Whereas Subrogation is the effect of the situation where a mortgage is redeemed by a person
other than the mortgagor, and he subrogated only to the rights of the mortgagor and no more.
While subrogation is not an assignment, in a broad sense subrogation may be considered as
assigning a cause of action by operation of law and typical contractual subrogation provisions
may use assignment language. Further assignment and subrogation may apply in a single case.
Contribution, Indemnity and Subrogation
Technically speaking, 'contribution' and 'indemnity' are mutually exclusive remedies but are
often asserted as alternative causes of action in the same lawsuit. 'Indemnity' shifting less than
complete liability is really contribution and 'contribution' shifting all liability is actually
indemnity.
Additionally, Contribution and indemnity actions sometimes appear to seek the same relief as
subrogation allows and are often asserted as alternative theories to subrogation recovery. The
distinction between contribution/indemnity and subrogation lies in the person claiming the right
and the person whose debt is paid is because contribution and indemnity require a common
liability with the one against whom contribution and indemnity are sought.

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CONCLUSION
Countries which have inherited the common law system will typically have a doctrine of
subrogation, though its doctrinal basis may be rationalised differently depending upon the extent
to which Equity remains a distinct body of law in that jurisdiction.
English courts have now accepted that the concept of unjust enrichment has a role to play in
subrogation. In contrast, this approach has been stridently rejected by the High Court of
Australia, where the doctrinal basis of subrogation is said to lie in the prevention of
unconscionable results: for example, the discharge of a debtor or one party getting double
recovery.
Supreme Court of India held that in the case of subrogation, Rights of Subrogation vests by
operation of law rather than as the product of express agreement. Right of Subrogation can be
enjoyed by the insurer as soon as payment is made, whereas an assignment requires an
agreement that the rights of the assured be assigned to the insurer. In the case of subrogation, the
assignee can recover whatever amount has been paid by him to the insurer whereas in the case of
assignment, he can recover more than the actual loss from the insurer/third party. Thus Supreme
Court of India came to the conclusion that the letter styled as "subrogation" was in fact
assignment of the rights by the insured and, therefore, the insurer was not a 'consumer' within the
meaning of the Consumer Protection Act, 1986 and, therefore, not entitled to maintain the
complaint. Where subrogation is available, the subrogated party is entitled to stand in the shoes
of another and enforce that other party's rights. If the equity is established, the court may effect
the subrogation remedy by way of equitable lien, charge, or a constructive trust with a liability to
account. Crucially, the claimant's rights are wholly derivative; hence the claimant has no higher
rights than the person to whom he or she is subrogated.

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BIBLIOGRAPHY

Mulla, The Transfer of Property Act, 9th Ed., LexisNexis Butterworths, 2004.

Nandi, N., The Transfer of Property Act, 1882, 2nd Ed., Dwivedi Law Agency,

Allahabad, 2010.
Row, Sanjiva, The Transfer of Property Act, 4th Ed., Vol. 1, The Law Book Company (P)

Ltd., Allahabad, 1989.

Sinha, Dr.R.K., The Transfer of Property Act, 11th Ed., Central Law Agency, Allahabad,

2010.
Sohoni, Vishwas Shridhar, Transfer of Property Act, Premier Publishing Company,

Allahabad, 2008.
The Transfer of Property Act, 1882, Bare Act, Universal Law Publishing Co. Pvt. Ltd.,

New Delhi, 2010.

Vakil, Darashaw J., Commentaries on the Transfer of Property Act, 2nd Ed., Wadhwa
and Company Nagpur, New Delhi, 2004.

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