Limitation and acknowledgment of debt: signed endorsement treated as sufficient admission under Section 19 despite Section 20 issue.

An endorsed part-payment that was signed but not in the debtor's handwriting did not satisfy the amended handwriting requirement under Section 20 to revive a debt already barred before the amendment took effect, because a procedural change does not revive an unenforceable claim absent clear legislative intent. The same endorsement, however, contained a sufficient admission of the balance due and could operate as an acknowledgment of liability under Section 19 on the principles applicable to the repealed provision. The suit dismissal was therefore not disturbed on the ground that the endorsement was ineffective.

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Issues: Whether an endorsement of part-payment, though insufficient under Section 20 of the Indian Limitation Act because it was signed but not in the debtor's handwriting, could nevertheless operate as an acknowledgment of liability under Section 19 of the Indian Limitation Act and save the claim.

Analysis: The amended law under Section 20 of the Indian Limitation Act relaxed the former requirement regarding handwriting or signature, but the amendment could not revive a debt already barred by limitation before the amendment came into force. A procedural statute may operate retrospectively, yet it does not revive an unenforceable right unless the statute clearly so provides. On the terms of the endorsement, however, the writing contained a sufficient acknowledgment of the balance due, and under the principles applicable to the repealed section it could be treated as an acknowledgment under Section 19.

Conclusion: The endorsement was a sufficient acknowledgment of liability under Section 19 of the Indian Limitation Act, and the dismissal of the suit could not be disturbed on the ground urged against the endorsement.

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