OM PRABHA JAIN vs GIAN CHAND & ANOTHER

The Supreme Court held that the deposit receipt for election petition compliance under Section 117 of the Representation of the People Act, 1951 must be interpreted to mean that the money was paid 'in favour of' the Secretary to the Election Commission, not 'on behalf of' him. The Court ruled that the Tribunal's dismissal of the election petition under Section 90(3) was incorrect, as the receipt complied with Section 117, and clarified that such dismissal is appealable under Section 116A. The Court disapproved of Harihar Singh v. Singh Ganga Prasad, A.I.R. 1958 Pat. 287, while relying on Harish Chandra Bajpai v. Triloki Singh, [1957] S.C.R. 370.