Sunday, August 31, 2008

Maxims of Equity

Maxims of Equity

 

1. EQUITY WILL NOT SUFFER A WRONG TO BE WITHOUT A REMEDY

 

Meaning

Where there is a right there is a remedy. This idea is expressed in the Latin Maxim ubi jus ibi remedium. It means that no wrong should go unredressed if it is capable of being remedied by courts. This maxim indicates the width of the scope and the basis of on which the structure of equity rests. This maxim imports that where the common law confers a right, it gives also a remedy or right of action for interference with or infringement of that right.

 

Application and cases

In Ashby v. White, wherein a qualified voter was not allowed to vote and who therefore sued the returning officer, it was held that if the law gives a man a right, he must have a means to maintain it, and a remedy, if he is injured in the enjoyment of it.

In cases where some document was with the defendant and it was necessary for the plaintiff to obtain its discovery or production, a recourse to the Chancery Courts had to be made for the Common Law becoming ‘wrongs without remedies’.

 

Limitation

a)   If there is a breach of a moral right only.

b)   If the right and remedy both were in within the jurisdiction of the Common Law Courts.

c)   Where due to his own negligence a party either destroyed or allowed to be destroyed, the evidence in his own favour or waived his right to an equitable remedy.

 

Recognition

i) The Trust Act

ii) Section 9 of CPC- entitles a civil court to entertain all kinds of suits unless they are prohibited.

iii) The Specific Relief Act- provides for equitable remedies like specific performance of contracts, injunction, declaratory suits.

 

 

2. EQUITY FOLLOWS THE LAW

 

Meaning

The maxim indicates the discipline which the Chancery Courts observed while administering justice according to conscience. As has been observed by Jekyll. M.R: ‘The discretion of the court is governed by the rules of law and equity, which are not to oppose, but each, in turn, to be subservient to the other.” Maitland said, “Thus equity came not to destroy the law but to fulfill it, to supplement it, to explain it.” The goal of equity and law is the same, but due to their nature and due to historic accident they chose different paths. Equity respected every word of law and every right at law but where the law was defective, in those instances, these Common Law rights were controlled by recognition of equitable Rights. Snell therefore explained this maxim in slightly different way: “Equity follows the law, but not slavishly, nor always.”

 

Application and cases

At common law, where a person died intestate who owned an estate in fee-simple, leaving sons and daughters, the eldest son was entitled to the whole of the land to the exclusion of his younger brothers and sisters. This was unfair, yet no relief was granted by Equity Courts. But in this case it was held that if the son had induced his father not to make a will by agreeing to divide the estate with his brothers and sisters, equity would have interfered and compelled him to carry out hi promise, because it would have been against conscience to allow the son to keep the benefit of a legal estate which he obtained by reason of his promise. This decision was held in Stickland v. Aldridge.

Equity follows the law and even if by analogy law can be followed, it should be followed.

 

Limitation

i) Where a rule of law did not specifically and clearly apply

ii) Where even by analogy the rule of law did not apply

 

Recognition

Bangladesh has not recognized the well-known distinction between legal and equitable interests. Equity rules in Bangladesh, therefore, cannot override the specific provisions of law. As for example, every suit in Bangladesh has to be brought within the limitation period and no judge can create an exception to this or can prolong the time-limit or stop the rule from taking effect on principles of equity. Such a decision was held in Indian Appa Narsappa Magdum case.

 

 

3. HE WHO SEEKS EQUITY MUST DO EQUITY

 

Meaning

The maxim means that to obtain an equitable relief the plaintiff must himself be prepared to do ‘equity’, that is, a plaintiff must recognize and submit to the right of his adversary. Scriptures of Islam also inform us to be conscientious:

“Woe to those who stint the measure:

Who when they take by measure from others, exact the full;

But when they mete to them or weigh to them, minish…”

 

Application and cases

This maxim has application in the following doctrines-

i) Illegal loans

ii) Doctrine of Election

iii) Consolidation of mortgages

iv) Notice to redeem mortgage

v) Wife’s equity to settlement

vi) Equitable estoppel

vii) Restitution of benefits on cancellation of transaction

viii) Set-off

 

i)      Illegal loans: In Lodge v. National Union Investment Co. Ltd., the facts were as follows. One B borrowed money from M by mortgaging certain securities to him. M was a unregistered money-lender. Under the Money-lenders’ Act, 1900, the contract was illegal and therefore void. B sued M for return of the securities. The court refused to make an order except upon the terms that B should repay the money which had been advanced to him.

 

ii)     Doctrine of election: Where a donor A gives his own property to B and in the same instrument purports to give B’s property to C, B will be put to an election, either accept the benefit granted to him by the donor and give away his own property to C or retain his own property and refuse to accept the property of A on condition. But B can not retain his property and at the same time take the property of A.

 

iii)    Consolidation of mortgages: Where a person has become entitled to two mortgages from the same mortgagor, he may consolidate these mortgages and refuse to permit the mortgagee to exercise his equitable right to redeem one mortgage unless the other is redeemed. The right of consolidation now exists in England but after the enactment of the Law of Property Act, 1925, it can exist only by express reservation in one of the mortgage deeds.

 

iv)    Notice to redeem mortgage: Notice to a mortgagor to redeem one’s mortgage is an equitable right of the mortgagor.

 

v)     Wife’s equity to a settlement: There was a time when woman’s property was merged with that of her husband. She had no property of her own. Equity court imposed on the husband that he must make a reasonable provision for his wife and her children. But, now, Under the Law Reform (Married Women and Tortfeasors) Act, 1935, married women has full right on her property and it is not consolidated with her husband’s property.

 

vi)    Equitable estoppel: A promissory estoppel arises where a party has expressly or impliedly, by conduct or by negligence, made a statement of fact, or so conducted himself, that another would reasonably understand that he made a promise thereon, then the party who made such promise has to carry out his promise.

 

vii)   Restitution of benefits on cancellation of transaction: It is proper justice to return the benefits of a contract which was voidable, and, equity enforced this principles in cases where it granted relief of rescission of a contract. A party can not be allowed to take advantage of his own wrong.

 

viii) Set-off:  Where there have been mutual credits, mutual debts or other natural dealings between the debtor and any creditor, the sum due from one party is to be set-off against any sum due from the other party, and only the balance of the account is to be claimed or paid on either side respectively.

 

Limitation

i) The demand for an equitable relief must arise from a suit that is pending.

ii) This maxim is applicable to a party who seeks an equitable relief.

 

Recognition

i) Under sec 19-A of the Contract Act, 1872 if a contract becomes voidable and the party who entered into the contract voids the contract, he has return the benefit of the contract.

ii) sec 35 of the Transfer of Property Act embodies the principle of election.

iii) Sec 51 and 54 of the Transfer of Property Act.

iv) In Order 8, Rule 6 of the CPC, the doctrine of Set-off is recognized.

 

 

4. HE WHO COMES INTO EQUITY MUST COME WITH CLEAN HANDS

 

Meaning

Equity demands fairness not only from the defendant but also from the plaintiff. It is therefore said that “he that hath committed an inequity, shall not have equity.” While applying this maxim the court believed that the behavior of the plaintiff was not against conscience before he came to the court.

 

Application and cases

In Highwaymen case, two robbers were partners in their own way. Due to a disagreement in shares one of them filed a bill against another for accounts of the profits of robbery. Courts of equity do grant relief in case of partnership but here was a case where the cause of action arose from an illegal occupation. So, the court refused to help them.

The working of this maxim could be seen while giving the relief of specific performance, injunction, rescission or cancellation.

 

Limitation

General or total conduct of the plaintiff is not to be considered. It will be seen whether he was of clean hands in the same suit he brought or not. Brandies J. in Loughran v. Loughran said that “Equity does not demand that its suitors shall have led blameless lives.”

 

Exception

i) If the transaction is a against public policy

ii) if the party repents for his conduct before his unjust plans are carried out.

 

Recognition

i) Section 23 of the Indian Trust Act- An infant can not setup a defence of the invalidity of the receipt given by him.

ii) Section 17, 18 and 20 of the Specific Relief Act, 1877- Plaintiff’s unfair conduct will disentitle him to an equitable relief of specific performance of the contract.

 

Distinction between maxim no. 3 and 4-

He who seeks equity must do equity

He who comes into equity must come with clean hands

i) It is applicable when both the plaintiff and the defendant have claims of equitable relief against each other.

i) It is applicable when the defendant has no separate claim to relief and the plaintiff’s conduct is unfair.

ii) It exposes the condition subsequent to the relief sought.

ii) It is a condition precedent to seeking equitable relief.

iii) It refers to the plaintiff’s conduct as the court thinks it ought to be, after he comes to the court.

iii) It refers to the plaitiff’s conduct before he   approaches the court.

iv) The plaintiff has to mould his behavior according to the impositions by the court.

iv) If the plaintiff’s conduct is unfair, it would not entitle him to the relief sought.

v) The plaintiff has an option or a choice before him either to submit to the conditions put by the court, or to get out of the court.

v) The conduct of the plaintiff snatched his choice from him. His equitable right therefore neither be recognized nor enforced.

vi) This maxim looks to the future.

vi) This maxim looks at the past.

 

 

5. DELAY DEFEATS EQUITIES

 

Meaning

A Latin term in this regard is “Vigilantibus, non dormentibus, jura subvenient.” which means “Equity aids the vigilant and not the indolent”. So, if one sleeps on his rights, his rights will slip away from him. Legal claims are barred by statutes of limitation and equitable claims may be barred not only by limitation law but also by unreasonable delay, called laches.

 

Application and cases

To cases which are governed by statutes of limitation either expressly or by analogy the maxim will not apply. Such cases fall into three categories-

i) Those equitable claims to which the statute applies expressly.

ii) to which the statute applies by analogy.

iii) Equitable claims which are covered by ordinary rules of laches.

Doctrine of laches- Plaintiff’s unreasonable delay is a weapon of defence by the defendant against the plaintiff.

In a Bombay case, the plaintiff allowed his land to be occupied by the defendant and this was acquiesced  by him even beyond the period of limitation. On a suit of the land it was decided that as the period of limitation to recover possession had expired, no relief could  be granted. Also the case of Allcard v. Skinner is worth mentioning here.

 

Limitation

This maxim does not apply when-

i) where the law of limitation expressly applies

ii) where it applies by analogy, and

iii) where the law of limitation does not apply but the cases are governed by ordinary rules of laches.

 

Recognition

The English doctrine of delay and laches showing negligence in seeking relief in a court of equity can not be imported into the Bangladeshi law in view of Article 113 of the Limitation Act, 1908, which fixes a period of one year (previously three years) within which a suit for specific performance should be brought.

Section 51 of the Transfer of Property Act embodies this doctrine but with a difference.

 

 

6. EQUALITY IS EQUITY

 

Meaning

Plato defined that “If you cannot find any other, equality is the proper basis.” This maxim is also explained as “equity delighteth in equality”, which means that as far as possible equity would put the litigating parties on an equal level so far as their rights and responsibilities are concerned.

Justice Fry said, “When I say equality, I do not mean equality in its simplest form, but which has been sometimes called proportionate equity.”

 

Application and cases

Application of this maxim can be understood from the following:

i)    Equity’s dislike for joint tenancy and presumption of tenancy-in-common

ii)   Equal distribution of joint funds and joint purchases

iii)   Contribution between co-trustees, co-sureties and co-contractors

iv) Ratable distribution of legacies

v)   Marshalling of assets

 

 

7. EQUITY LOOKS TO THE INTENT RATHER THAN THE FORM

 

Meaning

 

Common law was very rigid and inflexible. It could not respond favourably to the demand of time. It regarded the form of a transaction to be more important than its substance. It looked to the very letter of the agreement and not the intention behind it. On the other hand, Equity looks to the spirit not to the letter, it looks to the intention of parties and not to the words.

 

Application and cases

In case of sale of land, if a party fails to complete it within the fixed for it, he is at Common Law, in breach of the contract, but equity does not take this rigid attitude. It allows a reasonable time to the party to complete it.

The application can be seen in the following instances-

i)    Relief against penalties and forfeitures

ii)   Relief in regard to precatory trust

iii)   Relief in regard to mortgages, the doctrine of equity of redemption and the doctrine of clogs on redemptions

iv) Attitude in regard to statute of frauds.

 

i) Relief against penalties and forfeitures- Common Law courts insisted on the literal form of the contract that if the contract is breached, certain amount must be given as compensation, though the actual loss is not that much. Equity interpret the purpose and intent of the contract itself. The principal object of the contract is to perform it and not the compensation. The compensation is a subsidiary matter.

 

ii) Precatory trust- A trust is created with- (1) an intention on his part to create a trust thereby, (2) the purpose of the trust, (3) the beneficiary, and (4) the trust property. Where an author uses words such as ‘I hope’, ‘I request’ or ‘I recommend’ the first condition is missing. In cases where subsequent ingredients are found, in early days, it was held by the equity courts that he had the intention. This view is in use now but not as liberally as before.

 

iii) Relief in regard to mortgages- The mortgagor has a right to obtain his property back by payment of the debt and that is his right of redemption. The mortgagor’s right of redemption is guarded by courts and this has been expressed in a well-known legal maxim, “Once a mortgage, always a mortgage, and nothing but a mortgage”.

iv) Attitude in regard to statute of frauds-

 

Recognition

i) Sec 55 of the Contract Act- If time is the essence of the contract, and it is not performed within the stipulated time, the contract or part of it which is unperformed would be voidable. If time is not the essence, the contract will not be voidable but entitles the promisee to damages.

ii) Section 74 of the Contract Act- only a reasonable compensation can be claimed.

iii) Sec 114-A of the Transfer of Property Act- Forfeiture clauses in a lease.

 

 

8. EQUITY LOOKS ON THAT AS DONE WHICH OUGHT TO BE DONE

 

Meaning

If someone undertakes an obligation for the other, equity courts look on it as done and as producing the same results as if the obligation had been actually performed. Equity courts therefore look to the acts of the person bound by his conscience and interpret and construe them in such a way that they amount to what ought to be done.

 

Application and cases

If A makes T trustee leaving 50,000 Taka to purchase a land for the use of B. T does not purchase the land and by the time, B dies leaving all immovable property to X and all movable property to Y. Now, who should get the 50,000 Taka? Equity in such cases would definitely regard the purchase of land which ought to have been made as made. The money thus goes to X.

The working of this maxim can be seen-

i) the doctrine of conversion

ii) Executory contracts

iii) doctrine of part performance

 

i)   Doctrine of conversion- In the case of Lachmere v. Lady Lachmere, money was taken as land. Doctrine of conversion can convert the money into immovable property and immovable property into money.

ii) Executory contracts-

(a) Assignment of future property: When an assignment of property was made for consideration equity treated it as a contract to assign. When the property came into existence in such a contract it was treated as a complete assignment. As a leading case on this point, Holroyd v. Marshall can be cited.

(b)  Agreement for a transfer: In Walsh v. Lonsdale, it was decided that an agreement for lease could be treated as a lease in equity.

iii) Doctrine of part performance: Under the equitable doctrine of part performance contracts pertaining to land were allowed to be formed by oral evidence  where one of the parties did acts of pats performance. Maddison v. Alderson is a leading case on this point.

 

Recognition

Many of the doctrines of English equity have taken statutory form in Bangladesh. Insofar as equitable assignments are concerned no equitable estate is recognized in Bangladesh. A transfer of future property for consideration operates as a contract to be performed in future.

i) The Transfer of Property Act- A Contracts to sell Sultanpur to B. While the contract is still in force, he sells Sultanpur to C, who has notice of the contract. B may enforce the contract against C to the same extent as against A.

ii) The Specific Relief Act- Section 12 relating to the specific performance of part of a contract also illustrates the application of the maxim.

iii) The Trust Act- Where a person acquires property with notice that another person has entered into an existing contract affecting that property, the former must hold the property for the benefit of the latter.

 

 

9. EQUITY IMPUTES AN INTENTION TO FULFILL AN OBLIGATION

 

Meaning

Equity considered and estimated acts of parties. Thus where a person is under an obligation to do a certain act, and he does some other act which is capable of being regarded as an act in fulfillment of his obligation. In other words a person is presumed to do what he is bound to do.

In Sowden v. Sowden, a husband covenanted with the trustee of his marriage settlement to pay to them £50,000 to be laid out by them in purchase of land in a particular area D. He, in fact, never paid the sum, but after marriage purchased the land at D in his own name, for £50,000. He died and could not bring the land into settlement. Equity courts construed that he purchased land to fulfill his obligation.

 

Application and cases

i) Doctrine of performance and satisfaction

ii) Ademption

iii) Doctrine of presumption of advancement

iv) Relief against defective execution of power of appointment.

 

i) Doctrine of performance and satisfaction- Sowden v. Sowden and Lachmere v. Lady Lachmere cases are examples of performance. Satisfaction is the donation of a thing with it is to be taken in extinguishment of some prior claim of donee. This maxim is helpful where the presumed intention of the testator is to be found out; where the intention is express the maxim has no application.

ii) Ademption- Ademption is a transfer of property which operates as a complete or pro tanto substitution for a gift previously made by the will of the donor.

e.g. X by his will leaves his daughter Y one-third of his residuary estate. Thereafter on Y’s marriage X gives Y 20,000 Taka. X dies. 20,000 Taka is an ademption -complete or proportionately to the gift of one-third share of the residuary estate of X.

iii) Presumption of advancement- When a purchase or transfer of property without consideration is made by a father or a person in loco parentis, to or in the name of a child, a presumption arises. And the presumption is that it was for the benefit of the child. Such presumption, is known as ‘advancement’. The doctrine applies to cases of parent and child, husband and wife, of mother and child and even to illegitimate child, but not to a man and his mistress.

iv) Relief against defective execution of power of appointment- A power is an authority vested in a person to deal with or dispose of property not his own. A power may be legal or equitable but after 1925 all powers of appointment are necessarily equitable.

e.g. A holds 50,000 Taka upon trust to divide among a certain class of persons. A has no option is this matter He is bound to carry out the trust. On his failing to do so, the court will see that the property is duly divided.

A defective execution will always be aided in equity under the circumstances mentioned, it being the duty of every man to pay his debts, and a husband or a father to provide for child.

 

Recognition

i) The Succession Act- Presumption against satisfaction is mentioned here. In Hasanali v. Popatal, a testator, who had a sum of Rs 9000 as deposit from his brother, gave to is brother a legacy of Rs 9000 and it was held that the brother was entitled to both, the legacy and his deposit. But as decided in Rajmanuar case where a will contained a clear indication that the legacy was meant as a satisfaction of the debt due to X, X could not claim both as the section explains.

ii) The Trust Act- Where a person contracts to buy property to be held on trust for certain beneficiaries and buys the property accordingly, he must hold the property for their benefit to the extent necessary to give effect to the contract. Equity thus imputes an intention to fulfill an obligation.

The doctrine of advancement does not apply in Bangladesh.

102 comments:

  1. Splendid collection, best for the student

    ReplyDelete
  2. Very well structured and organized! I found it very helpful! Thank you!

    ReplyDelete
  3. Law student in Uganda and i have found this very useful..it is organised and easy to understand

    ReplyDelete
    Replies
    1. i am also a law student in Ghana..how about contacting me on syamewugah1@gmail.com and lets chat

      Delete
  4. plz i need notes of islamic law maxims and equity maxims comparison...

    ReplyDelete
  5. my id is kaleem8897@yahoo.com

    ReplyDelete
  6. This comment has been removed by the author.

    ReplyDelete
  7. Splendid collection, best for the student.Thanks.

    ReplyDelete
  8. Thankyou so very much this work has really helped in my revision on maxims of equity.

    ReplyDelete
  9. thanks 4 2 all who contribute knowledge

    ReplyDelete
  10. Wondafull job it's encouraging. Law students we should wake up.

    ReplyDelete
  11. You make a good job, nice to meat your frame work,hence we are in need of the remaining 3 you stop at 9 insted of 12.wish you the best. Nura Isa Abdullahi.B.u.k

    ReplyDelete
  12. this site was extremely helpfull =)

    ReplyDelete
  13. wow, good piece of work. God bless you

    ReplyDelete
  14. Am touch by the simplicity of the cases. May your knowledge in academia increase more and more. Thanks Matilda-Ghana

    ReplyDelete
  15. Great collection. Splendid work. I have found this very helpful.

    ReplyDelete
  16. hi
    if you need your academic papers on any course or subject written for you, or any type of articles and submitted at your convenient time, contact us at maxwellprofessionalwriters@gmail.com, we are a new generation writing company where we deal with clients directly as we have our own bunch or writers and aim at eliminating previously exploitation of clients and writers by companies simultaneously.
    working with us will be the best investment decision you make.
    best regards,
    ;-)

    ReplyDelete
  17. this is a nice art written by eligible scholars.kudos

    ReplyDelete
  18. I like the explanations 100%

    ReplyDelete
  19. Good work thnx alot

    ReplyDelete
  20. A work well done.

    ReplyDelete
  21. Thanks ,good work

    ReplyDelete
  22. splendid. Good illustrations.. Daniel-Ghana

    ReplyDelete
  23. wel done i am law student i want every mater and units trust legal methos plz send me my email this type knnan7022@gmail.com from srianka

    ReplyDelete
  24. wel done i am law student i want every mater and units trust legal methos plz send me my email this type knnan7022@gmail.com from srianka

    ReplyDelete
  25. Thanks for finally talking about > "Maxims of Equity" < Liked it!

    My site ... how To
    detox your Body

    ReplyDelete
  26. very good but it has miss 3 maxims but this is useful to us Thank you

    ReplyDelete
  27. Hi there, its good paragraph about media print, we all be aware of media is a great
    source of data.

    my web site ... World Of Tanks Hack
    my site :: World Of Tanks Hack

    ReplyDelete
  28. Best ever handout

    ReplyDelete
  29. Hi there everyone, it's my first pay a visit at this website, and piece of writing is genuinely fruitful for me, keep up posting these articles.

    Have a look at my homepage :: Simply click The next document - www.youtube.com

    ReplyDelete
  30. I would like to thank you for the efforts you have put in penning this website.
    I really hope to check out the same high-grade blog posts by you later on as
    well. In truth, your creative writing abilities has motivated me
    to get my very own site now ;)

    My weblog; how to lose belly fat

    ReplyDelete
  31. If you want to improve your know-how simply keep visiting this site and be updated
    with the most up-to-date gossip posted here.

    Also visit my blog post: sian

    ReplyDelete
  32. Hey There. I found your weblog using msn.
    That is a very neatly written article. I will make sure to
    bookmark it and come back to read more of your helpful info.

    Thank you for the post. I will definitely return.

    Feel free to surf to my website :: more bonuses

    ReplyDelete
  33. Realy nice and very helpful for the student......... Thanks at all.

    ReplyDelete
  34. I have a grinding noise that is keeping me from publishing everything from the Cyan toner.
    Could this be the same case?

    Also visit my web page; xerox phaser 8560dn

    ReplyDelete
  35. Sooo explicit. Thanks

    ReplyDelete
  36. Right here is the perfect web site for anyone who wishes to find
    out about this topic. You know a whole lot its almost hard to argue with you (not
    that I actually will need to…HaHa). You certainly put a new spin on a topic that's been discussed for ages. Great stuff, just excellent!

    Also visit my page ... unknown

    ReplyDelete
  37. Great post.

    Here is my blog post - unknown

    ReplyDelete
  38. Wonderful post! We will be linking to this great content on our site.
    Keep up the great writing.

    Feel free to surf to my weblog - How To Lose Belly Fat

    ReplyDelete
  39. Fuh ... done it. Put up Samsung Universal vehicle driver and home windows 8 considered
    it better vehicle driver, though it never functioned.
    It can be deleted trough the Control board -) Programs and something.
    After that simply observe Aaron information. Enjoyable .
    .. Thanks !!! ).

    My blog Xerox Phaser 8560

    ReplyDelete
  40. Please let me know if you're looking for a article author for your weblog. You have some really good articles and I think I would be a good asset. If you ever want to take some of the load off, I'd absolutely love to write some articles for your blog in exchange for
    a link back to mine. Please blast me an email if interested.
    Thank you!

    Also visit my webpage - unknown

    ReplyDelete
  41. Hey! I know this is kinda off topic but I was wondering
    if you knew where I could find a captcha plugin
    for my comment form? I'm using the same blog platform as yours and I'm having problems finding one?
    Thanks a lot!

    Look into my web site :: stretch marks

    ReplyDelete
  42. My brother recommended I might like this web site. He was once entirely right.
    This put up actually made my day. You cann't imagine just how so much time I had spent for this info! Thanks!

    My homepage: Pirater un compte facebook

    ReplyDelete
  43. I savor, cause I discovered exactly what I was
    looking for. You've ended my four day long hunt! God Bless you man. Have a nice day. Bye

    Have a look at my webpage :: Http://En.Netlog.com/roxanaabner/blog/blogid=21720578

    ReplyDelete
  44. Fantastic blog! Do you have any tips and hints for aspiring writers?
    I'm hoping to start my own site soon but I'm a little lost on everything.
    Would you propose starting with a free platform like Wordpress or go
    for a paid option? There are so many choices out
    there that I'm completely confused .. Any suggestions? Kudos!

    Here is my web page - Unknown

    ReplyDelete
  45. whoah this blog is great i love studying your articles.
    Keep up the great work! You recognize, a lot of persons are hunting round for this info,
    you could aid them greatly.

    Feel free to visit my website www.dailymotion.com

    ReplyDelete
  46. This post provides clear idea in favor of the new viewers of blogging, that truly how to
    do blogging.

    Visit my website tattoo removal cream reviews

    ReplyDelete
  47. If you would like to grow your familiarity just keep visiting this site
    and be updated with the latest information posted here.


    Here is my blog post :: coconut oil for hair

    ReplyDelete
  48. Can I simply say what a relief to discover somebody that really knows what they are discussing on the internet.
    You certainly know how to bring an issue to light and make it important.

    A lot more people should read this and understand this side of
    the story. I can't believe you're not more popular since you certainly have the gift.


    Also visit my webpage :: Diaper Rash Remedies

    ReplyDelete
  49. I love your blog.. very nice colors & theme. Did you design this website yourself or
    did you hire someone to do it for you? Plz answer back as I'm looking to create my own blog and would like to find out where u got this from. thank you

    my web-site; Psn Code Generator

    ReplyDelete
  50. Hi, I do think this is an excellent blog. I stumbledupon it ;) I may
    return yet again since i have bookmarked it.
    Money and freedom is the best way to change, may you be rich and continue to guide others.


    Feel free to surf to my web-site :: Microsoft Office Gratuit

    ReplyDelete
  51. Hello, every time i used to check webpage posts here in the early hours
    in the break of day, since i enjoy to learn more and more.


    Here is my page: Persistent Diarrhea

    ReplyDelete
  52. Hello to every single one, it's truly a pleasant for me to go to see this web site, it contains useful Information.

    Here is my weblog: ps3 Jailbreak 4.41

    ReplyDelete
  53. This website definitely has all of the information and facts I needed about this subject and didn't know who to ask.

    My web blog microsoft points

    ReplyDelete
  54. Good day I am so happy I found your weblog, I really found you by accident,
    while I was browsing on Askjeeve for something else, Anyways I am here now and
    would just like to say many thanks for a tremendous
    post and a all round enjoyable blog (I also love the theme/design), I don’t have time to read it all at the minute but I have book-marked it and
    also added your RSS feeds, so when I have time I will
    be back to read a great deal more, Please do keep up the fantastic b.


    my homepage :: Ps3 jailbreak download

    ReplyDelete
  55. Please let me know if you're looking for a writer for your weblog. You have some really great articles and I believe I would be a good asset. If you ever want to take some of the load off, I'd love to write some articles for your blog in
    exchange for a link back to mine. Please blast me an e-mail
    if interested. Many thanks!

    Take a look at my website; Www.Dailymotion.Com

    ReplyDelete
  56. I every time emailed this webpage post page to all my friends, as if
    like to read it after that my links will too.

    My homepage :: Dragon City Hack

    ReplyDelete
  57. very good and helping notes thanks

    ReplyDelete
  58. raelly , amazing notes its help me vry much

    ReplyDelete
  59. u have done a goood work

    ReplyDelete
  60. It's actually very complex in this full of activity life to listen news on TV, therefore I just use world wide web for that purpose, and get the latest information.

    Feel free to surf to my weblog ... psn Code Generator

    ReplyDelete
  61. you're actually a excellent webmaster. The web site loading speed is amazing. It kind of feels that you are doing any unique trick. Furthermore, The contents are masterwork. you have done a fantastic process on this matter!

    Visit my homepage: Psn Code Generator

    ReplyDelete
  62. Hi, I think your blog might be having browser compatibility problems.
    Whenever I look at your website in Safari, it looks fine however, when opening in
    Internet Explorer, it has some overlapping issues.
    I merely wanted to give you a quick heads up! Aside from that, excellent
    website!

    My web page ... Free Psn Codes

    ReplyDelete
  63. Your mode of explaining everything in this article is really pleasant, every one be able to effortlessly be aware of it, Thanks a lot.



    Also visit my weblog - Code Psn Gratuit

    ReplyDelete
  64. Thank you a bunch for sharing this with all of us you actually realize what
    you're talking about! Bookmarked. Kindly also visit my site =). We will have a link trade contract among us

    My blog post ... World Of Tanks Hack

    ReplyDelete
  65. Wonderful article! This is the kind of info that are meant to be shared around the
    web. Shame on Google for now not positioning this submit higher!
    Come on over and talk over with my web site . Thank you =)

    Feel free to visit my web page - Free Psn Codes

    ReplyDelete
  66. Everything is very open with a really clear clarification of the issues.
    It was definitely informative. Your site is very
    helpful. Many thanks for sharing!

    Here is my homepage :: Code Psn Gratuit

    ReplyDelete
  67. Outstanding post but I was wondering if you could write a litte more on this topic?
    I'd be very grateful if you could elaborate a little bit more. Many thanks!

    Feel free to surf to my weblog; Minecraft Crack

    ReplyDelete
  68. Awesome creation of maxim.simple,easy and short

    ReplyDelete
  69. Good work with great precision. Well done ~ Alberta, Ghana

    ReplyDelete
  70. Great work hats off to you !

    ReplyDelete
  71. thanks for this good work,keep it up.

    ReplyDelete
  72. This comment has been removed by the author.

    ReplyDelete
  73. Thank you you! :)
    God shall bless you for your thoughtfulness. This is very helpful!

    ReplyDelete
  74. This comment has been removed by the author.

    ReplyDelete
  75. Nice work, best regards for a job well done

    ReplyDelete
  76. work is best,Alhamdullillah

    ReplyDelete
  77. Great... Much more than average...

    ReplyDelete
  78. This is a great job.... More grace to your elbow

    ReplyDelete
  79. Allow me to start by appreciating the legal Minds behind this well thought of Legal Material and ask the lord to reward you for being supportive both the law students and the society at large. However i kindly request you that you open up an account where right thinking Members can deposit some small amounts of money that will enable you execute and deliver to the world legal updates with easy. Thank you. Adam Zziwa Mbiringi. Okiriata@yahoo.com

    ReplyDelete
  80. easy note...i think it will help to every law student to understand law of equity easily!

    ReplyDelete
  81. very useful document. thanks a lot.

    ReplyDelete
  82. Lovely work (y)

    ReplyDelete
  83. pls provide for gujarat university

    ReplyDelete