Share transfer and unpaid price: title passed on completion, leaving the seller to pursue price or damages, not injunction.

Transfer documentation and statutory company records showed the share transfer had been completed after board approval, with the defendant recorded as shareholder. Under the Sale of Goods Act, mere non-payment or postponement of price did not prevent title from passing where specific goods were transferred in a deliverable state without reservation of disposal. Once transfer was complete, the seller's remedies lay as an unpaid seller for price or damages, not in retaining title or seeking to restrain dealings with the shares. The plaintiff's earlier inconsistent pleadings also weakened the request for interim relief, and the injunction application was rejected.

---

---

Issues: Whether the plaintiff was entitled to an ad interim injunction restraining the defendant from dealing with the disputed shares on the ground that title had not passed because the stated sale consideration was allegedly unpaid.

Analysis: The transfer documentation, including the duly executed share transfer form, recorded the consideration as received, and the company's statutory records reflected the defendant as a shareholder after board approval. The transfer was therefore treated as having been completed through the statutory share-transfer process. Under the Sale of Goods Act, 1930, the mere postponement or non-payment of price does not prevent title from passing where the contract is for specific goods in a deliverable state and there is no reservation of disposal. Once the seller has delivered the shares and the transfer is complete, the seller's remedies are those of an unpaid seller for the price or damages, not a claim to retain title. The plaintiff's own earlier pleadings in related proceedings also contradicted the present stand and undermined the request for interim relief.

Conclusion: The plaintiff was not entitled to interim injunction relief and the application was rejected.

---