Statutory interest claim fails after unconditional acceptance of principal; later law does not revive settled liabilities.

Unconditional receipt of the principal amount in full discharge leaves no surviving substantive claim for interest alone under the Interest on Delayed Payments to Small Scale and Ancillary Industrial Undertakings Act, 1993. The court read the statutory scheme as requiring an existing amount due as the basis for recovery, so a suit confined only to interest was not maintainable after the principal had been paid and accepted without protest. The Act was also treated as prospective and was held not to revive claims that had already been settled or discharged before its commencement.

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Issues: (i) whether a supplier, after receiving the principal amount without reservation, can maintain a suit only for interest under the Interest on Delayed Payments to Small Scale and Ancillary Industrial Undertakings Act, 1993; (ii) whether the Act revived claims that had already been satisfied before its commencement.

Issue (i): whether a supplier, after receiving the principal amount without reservation, can maintain a suit only for interest under the Interest on Delayed Payments to Small Scale and Ancillary Industrial Undertakings Act, 1993

Analysis: The claim was founded on delayed payment of bills for supply of goods, but the admitted position was that the entire principal amount had already been paid and accepted without protest or reservation. The statutory scheme permits recovery of the amount due together with interest, and the court read this as requiring an existing amount due from the buyer as the foundation for a suit. On the facts, once the principal stood discharged in full, there was no surviving substantive claim to support an independent suit only for interest.

Conclusion: The suit for interest alone was not maintainable.

Issue (ii): whether the Act revived claims that had already been satisfied before its commencement

Analysis: The court treated the legislation as prospective and held that claims already settled or discharged before the Act came into force could not be given a fresh lease of life merely because the statute later created a right to interest on delayed payments. The absence of any reservation when the principal was accepted reinforced that the earlier transactions had reached full discharge and were not reopened by the statute.

Conclusion: The Act did not revive claims already satisfied before its commencement.

Final Conclusion: The decree was set aside, the suit was dismissed, and the appellant succeeded on the ground that no independent claim for interest survived after unconditional receipt of the principal and the statute did not operate to reopen settled liabilities.

Ratio Decidendi: A claim for statutory interest cannot be maintained after unconditional acceptance of the principal amount in full discharge, and a later-enacted statute will not revive liabilities already settled before its commencement.

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