JUDGMENT : UMA SHANKER VYAS, J. "29. It is apparent from the amended provisions of Order 41 Rule 22 CPC and the above authorities that there are two changes that were brought by the 1976 Amendment. First, the scope of filing of a cross-objection was enhanced substantively to include objections against "findings" of the lower court; second, different forms of raising cross-objections were recognised. The amendment sough to introduce different forms of cross-objection for assailing the findings and decrees since the amendment separates the phrase "but may also state that the finding against him in the court below in respect of any issue ought to have bee in his favour" from "may also take any cross- objection to the decree" with a semi colon. Therefore, the two parts of the sentence must be read disjunctively. Only when a part of the decree has been assailed by the respondent, should a memorandum of cross-objection be filed. Otherwise, it is sufficient to raise a challenge to an adverse finding of the court of first instace before the appellate court without a cross-objection." 1. Kale and others vs. Deputy Director of Consolidation and others AIR 1976 SC 807 ; 2. Hari Shankar Singhania and others Vs. Gaur Hari Singhania and others 2006(4) SCC 658 ; 3. Roshan Singh and ors. vs. Zile Singh and ors. (2018) 14 SCC 814 & 4. Thulasidhara and another vs. Narayanappa and others (2019) 6 SCC 409 "2 (15) Instrument of partition - " instrument of partition" means any instrument whereby co-owners of any property divide or agree to divide such property in severalty, and includes also a final order for effecting a partition passed by any revenue-authority or any Civil Court and an award by an arbitrator directing a partition; "(15) 'Instrument of partition' , means any instrument whereby co-owners of any property divide or agree to divide such property in severality and includes- (i) a final order for effecting a partition passed by any revenue authority, or any Civil court. (ii) an award by an arbitrator directing a partition, and (iii) when any partition is effected without executing any such instrument any instrument or instruments signed by the co- owners and recording whether by way of declaration of such partition or otherwise the terms of such partition amongst the co- owners."