Kedarnath Agarwal (dead) & Anr.v Dhanraji Devi (dead) by lrs & Anr. (2004) 8 SCC 76 Editorial : The Bombay High Court has followed the above principle in the case of Sushila Shantilal Jhaveri vs. UOI & Anr (2006) 286 ITR 428 (Bom) (HC)

Uttar Pradesh Urban Buildings (Regulation of letting ,Rent and Eviction) Act ,1972

S.21: Subsequent event should be considered by courts-It is necessary to do so in order to do complete justice between parties – Test laid down:

The basic rule is that the rights of the parties should be determined on the basis of the date of institution of the suit or proceeding, however a court of law may take into account subsequent events inter alia in the following circumstances:.

  1. the relief claimed originally has by reason of subsequent change of circumstances become inappropriate; or
  2. it is necessary to take notice of subsequent events in order to shortern litigation; or
  3. it is necessary to do so in order to do complete justice between the parties