Written assignment is required to transfer insurance policy proceeds; mere deposit of the policy creates no enforceable interest.

An actionable claim, including the right to money payable under an insurance policy, can be transferred only by a written instrument signed by the transferor or authorised agent. Mere deposit of the policy without writing does not create any enforceable charge, interest, or transfer in the policy or its proceeds, whether the arrangement is intended as security or an absolute transfer. A valid written assignment, however, operates to vest the transferor's rights in the transferee and entitles the transferee to the proceeds.

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Issues: Whether the respondent acquired any enforceable right in the insurance policy or its proceeds by mere deposit of the policy without a written transfer, and whether the appellant's written assignment entitled him to the proceeds.

Analysis: Section 130(1) of the Transfer of Property Act, 1900 governs transfer of an actionable claim and makes such transfer effective only by execution of a written instrument signed by the transferor or his authorised agent. The right to monies payable under the policy is an actionable claim, and the section applies equally to transfers by way of security and absolute transfers. A mere deposit of the policy, unaccompanied by writing, cannot create a charge or transfer any interest in the policy or its proceeds. By contrast, a written assignment complying with the section operates to vest the transferor's rights in the transferee.

Conclusion: The respondent acquired no right to the policy or its proceeds by deposit alone, while the appellant acquired the right to the proceeds under the written assignment.

Ratio Decidendi: An actionable claim can be transferred only by a written instrument as required by Section 130(1) of the Transfer of Property Act, 1900, and a mere deposit of the chose in action without writing does not create any enforceable charge or interest.

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