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Issues: Whether a displaced creditor could maintain an application under section 13 of the Displaced Persons (Debts Adjustment) Act, 1951 against the State of Punjab, and whether a debt due from the State could fall within the Act by necessary implication.
Analysis: The expression "person" in section 13 and the definition of "debt" in section 2(6)(c) did not expressly name the State, but the Act had to be read as a whole. The scheme of sections 5, 11, 32 and 47 showed that debts owed by the State were required to be taken into account for determining a displaced debtor's assets and paying capacity, and the Act would be rendered unworkable if such debts were excluded. The beneficent object of the legislation, meant to relieve displaced persons after partition, would be frustrated unless the Government was bound. The earlier procedural legislation and the construction placed upon it did not control the later and broader Act of 1951.
Conclusion: The State was bound by the Act by necessary implication, and an application under section 13 was maintainable against it.
Ratio Decidendi: A statute of beneficent purpose will bind the State if, on a construction of its language, scheme and object, exclusion of the State would wholly frustrate the legislative intent and render the statutory machinery unworkable.