MUKTI LAL AGARWALA vs TRUSTEES OF THE PROVIDENT FUND OFTHE TIN PLATE CO. OF IND

The Supreme Court held that amounts in a Provident Fund account of insolvent employees are considered property under Section 4 of the Provincial Insolvency Act, 1920, despite being payable only upon certain contingencies. The Court clarified that subscribers have a present interest in the Fund, which constitutes a debt due from the company, thus making it liable for attachment and sale by creditors. The ruling emphasized that an individual's title cannot cease upon bankruptcy, as this would contravene insolvency law principles.