JUDGMENT : The legality of the successive appointments of powers-of-attorney by a party to the proceedings is under challenge in this Original Petition. The petitioner is the plaintiff in O.S.No.51 of 2014 on the file of the Additional Sub Court-I, Thiruvananthapuram. The respondent is the defendant. 2. On 17.02.2014, the defendant executed a power-of-attorney in favour of one Sivadasan Nair authorising him to prosecute for and on behalf of her. On 02.03.2019, she executed another power of attorney in favour of one Sri. S. Pradeep. On 12.07.2021, she executed a power-of-attorney in favour of one Sri. R. Anilkumar to prosecute the matter. 3. The trial Court accepted the third power-of-attorney holder, Sri.R.Anilkumar, as the agent of the defendant. The plaintiff filed I.A.No.8 of 2021 seeking review of the order accepting Shri. Anilkumar, as the agent of the defendant. 4. The plaintiff contended that without revoking the prior powers-of-attorney executed by the defendant, the defendant could not appoint another power-of-attorney holder to act as her agent. 5. The defendant resisted the application, contending that as per order dated 21.06.2022 in I.A.No.6 of 2021, the trial Court accepted the power-of-attorney executed in favour of Sri. R. Anilkumar and permitted him to act for and on behalf of her. The defendant further pleaded that the powers-of-attorney executed by her are revocable and there was no requirement to inform the prior power-of-attorney holders regarding the subsequent appointment. 6. The trial Court dismissed that application. 7. I have heard the learned counsel for the petitioner/the plaintiff, Advocate Sri. M.R. Sasi, the learned Amicus Curiae, and the learned counsel for the respondent/defendant. 8. The learned counsel for the petitioner relied on Rules (1) and (2) of Order III of the CPC to contend that the statutory provisions indicate that there shall be an express revocation for appointing a subsequent power-of- attorney to act as an agent. The learned counsel submitted that the recognized power-of-attorney holder is akin to the recognized agent, as provided in Rule 2 of Order III. The learned counsel relied on Janki Vashdeo v. Indusind Bank, [ 2005 (2) KLT 265 SC] to support his his contentions. 9. The learned Counsel for the defendant submitted that express revocation is not the mandate of Law. The conduct of the principal would necessitate an implied revocation of the power-of-attorney. 10. The learned Amicus Curiae extensively addressed arguments on the question of law. 9. The learned Counsel for the defendant submitted that express revocation is not the mandate of Law. The conduct of the principal would necessitate an implied revocation of the power-of-attorney. 10. The learned Amicus Curiae extensively addressed arguments on the question of law. The learned Amicus has taken me to the various provisions in the Indian Contract Act, 1872 , (‘Contract Act' for short) and the Powers-of-Attorney Act, 1882 . 11. The learned Amicus, relying on Section 207 of the Indian Contract Act, submitted that revocation or renunciation may be expressed or implied in the conduct of the principal or agent, respectively. The learned Amicus added that notice of revocation is required only where the agent himself has an interest in the property, which forms the subject matter of the agency. The learned Amicus submitted that in cases where the agents/power-of-attorney holders have created a liability to a third party, then also notice is required. Relying on Section 208 of the Contract Act, the learned Amicus submitted that the twin conditions for revocation are:- (i) communication to the agent and (ii) knowledge to a third party. 12. The learned Amicus submitted that in the present case, those communication and knowledge are implied. 13. The following facts are not in dispute:- (a)The power-of-attorney holders successively appointed by the defendant had no interest in the property which formed the subject matter of the suit. (b)The first and second power-of-attorney holders have not created any liability towards a third party. 14. 'Power-of-attorney' is defined in Section 1-A of the Powers-of-Attorney Act, 1882 . Section 1-A reads thus:- “...“power-of-attorney” includes any instrument empowering a specified person to act for and in the name of the person executing it.” 15. In Stroud's "Judicial Dictionary", power-of-attorney is defined as "an authority whereby one is set in the tune/stead or place of another to act for him." Black's Law Dictionary describes it as 'the instrument by which a person is authorised to act as an agent of the person granting it.' 16. The power-of-attorney must be in writing. It may be general or special. A general power of attorney authorises the agent to act for his Principal in all matters of a particular nature or generally in respect of a particular business, whereas a special power of attorney authorises the agent to represent his principal only in regard to some specific act. The power-of-attorney must be in writing. It may be general or special. A general power of attorney authorises the agent to act for his Principal in all matters of a particular nature or generally in respect of a particular business, whereas a special power of attorney authorises the agent to represent his principal only in regard to some specific act. A power of attorney expires with the death of the principal and is revocable at his will, even by verbal notice, unless it has been given for a valuable consideration to secure some interest of the donee. 17. The Law of agency, is the substantive law applicable to the Principal-Agent relationship. 'Agency' under the Law of Agency is akin to the power-of-attorney under the Powers-of-Attorney Act, and the relevant principles are applicable to the Principal-Agent relationship under a power-of-attorney. 18. Revocation of authority is dealt with in Sections 201 to 208 of the Indian Contract Act, 1872 . The relevant provisions in the Contract Act are extracted hereunder:- “201. Termination of agency .--An agency is terminated by the principal revoking his authority; or by the agent renouncing the business of the agency; or by the business of the agency being completed; or by either the principal or agent dying or becoming of unsound mind; or by the principal being adjudicated an insolvent under the provisions of any Act for the time being in force for the relief of insolvent debtors. 202.Termination of agency, where agent has an interest in subject-matter.-- Where the agent has himself an interest in the property which forms the subject-matter of the agency, the agency cannot, in the absence of an express contract, be terminated to the prejudice of such interest. 206. Notice of revocation or renunciation.-- Reasonable notice must be given of such revocation or renunciation; otherwise the damage thereby resulting to the principal or the agent, as the case may be, must be made good to the one by the other. 207. Revocation and renunciation may be expressed or implied.-- Revocation and renunciation may be expressed or may be implied in the conduct of that principal or agent respectively. 207. Revocation and renunciation may be expressed or implied.-- Revocation and renunciation may be expressed or may be implied in the conduct of that principal or agent respectively. 208.When termination of agent’s authority takes effect as to agent, and as to third persons.-- The termination of the authority of an agent does not, so far as regards the agent, take effect before it becomes known to him, or, so far as regards third persons, before it becomes known to them.” 19. A reading of Sections 201 and 207 of the Contract Act indicates that an agency is terminated by the principal revoking his authority, and the revocation or renunciation may be expressed or implied in the conduct of the principal or agent. Section 202 says that where the agent has himself an interest in the property which forms the subject-matter of the agency, the agency cannot, in the absence of an express contract, be terminated to the prejudice of such interest. In such a situation, as per Section 206 of the Act, a reasonable notice must be given of such revocation or renunciation. 20. Section 208 makes it clear that the termination of the authority of an agent does not, so far as regards the agent, take effect before it becomes known to him, or, so far as regards third persons, before it becomes known to them. As per Section 208, revocation takes effect upon two conditions being satisfied; (i) communication to the agent (ii) knowledge to a third party who deals with or is likely to deal with the agent. 21. The learned Amicus Curiae has taken me to the various authorities on the subject. 22. In D eb Ratan Biswas & Ors. v. Most. Anand Moyi Devi & Ors., [2011 SCC OnLine SC 633], the Supreme Court observed thus:- “12…...It is well-settled that even after execution of a power of attorney the principal can act independently and does not have to take the consent of the attorney. The attorney is after all only an agent of the principal. Even after executing a power of attorney the principal can act on his own” 23. Following the dictum laid down in Deb Ratan Biswas, in Thankamma George v. Lilly Thomas [ AIR 2024 SC 3706 : 2024 INSC 494 ], the Supreme Court observed thus:- “ 21. The attorney is after all only an agent of the principal. Even after executing a power of attorney the principal can act on his own” 23. Following the dictum laid down in Deb Ratan Biswas, in Thankamma George v. Lilly Thomas [ AIR 2024 SC 3706 : 2024 INSC 494 ], the Supreme Court observed thus:- “ 21. In the absence of a particular mode suggested for revocation of the authority of an agent, the manner adopted by the principal to revoke the authority of the agent must be one which clearly and unequivocally communicates to the parties i.e., to be affected by such revocation, that the agent's authority has been withdrawn. In the framework of Sections 207 and 208 of the Act, the revocation/renunciation of authority may be made by express words or may be implied from the words and conduct of the principal, viz., which is inconsistent with the continuance of the agency. This is one facet of renunciation or revocation of authority of an agent; the other facet is governed by Section 208 of the Act. Section 208 provides for the effective time and date of termination of the agent's authority and third parties. From a plain reading, Section 208 infers and gives effect to revocation upon the twin conditions being satisfied, (i) communication to the agent and (ii) knowledge to a third party i.e., one who deals with or is likely to deal with the agent. Then, the revocation of authority becomes known to the agent and the said third parties. In other words, an idea in the mind of the principal to revoke cannot be construed as implied revocation or renunciation of agency. There ought to be an act or conduct of the principal which implies that the agency is revoked or withdrawn. If the revocation is expressed, such as by publication in newspapers, public notice or advertisement, communication to the agent etc., the parties who deal with the agent have a reasonable opportunity to know the revocation of agency by the principal. Two stages of revocation are, firstly, one dealing with the agent, and secondly, one which applies to the third parties. If the revocation is expressed, such as by publication in newspapers, public notice or advertisement, communication to the agent etc., the parties who deal with the agent have a reasonable opportunity to know the revocation of agency by the principal. Two stages of revocation are, firstly, one dealing with the agent, and secondly, one which applies to the third parties. For attracting the consequence of revocation to either of the situations, the revocation of the agent's authority is made by the principal in a manner that clearly implies that the principal has withdrawn the authority to act on his or her behalf by the agent. Followed by knowledge to third parties, let us examine the circumstances of the case on whether implied revocation coupled with communication is established.” 24. In M.S. Ananthamurthy & Anr. V. V.J. Manjula, [2025 SCC OnLine SC 448], the Supreme Court observed thus:- “33. Section 201 of the Contract Act prescribes various ways of revocation of authority given by the principal to his agent. A principal can terminate the contract of agency unless such revocation is precluded by Section 202 of the Contract Act. Section 202 of the Contract Act, as an exception to the general rule under Section 201, prescribes that where an agent has himself an interest in the property which forms the subject-matter of the agency, the agency cannot be terminated to the prejudice of such interest unless there is an express stipulation to the contrary. 34. Illustration (a) to Section 202 of the Contract Act states that A (principal) has given authority to B (agent) to sell A's land, and to pay himself i.e., the agent, from the proceeds the debt which is due to him from A. Illustration (b) states that A (principal) has consigned 1,000 bales of cotton to B (agent), who has given an advance on the bales of cotton. Now, A wishes B to sell the cotton and recover his advance from the sale proceeds. In both the cases, A can neither revoke the authority nor agency will be terminated by his insanity or death. It is important to take a note that in both the cases, the agent has an interest vested in the subject-matter of the agency. Now, A wishes B to sell the cotton and recover his advance from the sale proceeds. In both the cases, A can neither revoke the authority nor agency will be terminated by his insanity or death. It is important to take a note that in both the cases, the agent has an interest vested in the subject-matter of the agency. The factum of interest or security of the agent, in both cases, does not imply that the agent's right to remuneration constitutes an interest in the subject matter of the agency; rather, it extends beyond the mere advancement of remuneration or commission. Where POA is coupled with an interest, it metamorphosizes to an irrevocable agency unless expressly stated otherwise. There an agent's right to remuneration is not an interest in the subject-matter of the agency. 35. Therefore, the essentials of Section 202 of the Contract Act are, first, there shall be a relationship in the capacity of ‘principal and agent’ between the parties and secondly, there shall be agent's interest in the subject- matter of the agency. If both the conditions are fulfilled the agency becomes irrevocable and cannot be terminated unilaterally at the behest of the principal. As the first condition is satisfied in the present case, we shall now proceed to examine whether from the reading of the GPA, the holder of POA had an interest in the subject matter of the agency, namely, the Suit Property.” 25. In V.A.Babu (Died) Lrs Jessy Babu and others v. M.V. Ayyappankutty and Another, [2007(3) KHC 873], this Court held thus:- 10 ……. Power of attorney is only an instrument by which a principal agent relationship is created between two parties and the agent is authorised to perform certain act or acts for and on behalf of the principal. The relationship between the principal and agent is fiduciary in nature and the normal rule is that the relationship is personal to the agent and the principal and being founded on mutual trust can be revoked when either of them loses faith in the other. The relationship will normally come to an end with the demise of either of them. S.202 provides an exception to the normal rule lest a unilateral revocation of the agency should cause prejudice to the entrusted agent who is having an interest in the subject matter of the agency…… 26. The relationship will normally come to an end with the demise of either of them. S.202 provides an exception to the normal rule lest a unilateral revocation of the agency should cause prejudice to the entrusted agent who is having an interest in the subject matter of the agency…… 26. The foregoing discussions lead to the following conclusions:- (a)Even after the execution of a power-of-attorney, the principal can act independently and does not have to take the consent of the attorney. (b)The revocation/renunciation of authority may be made by express words or may be implied from the words and conduct of the principal. (c)There ought to be an act or conduct of the principal which implies that the agency is revoked or withdrawn, followed by knowledge to third parties who deal with or are likely to deal with the agent. (d)In cases where agents' interest is attached to the subject-matter of the agency, unilateral termination of the agency at the behest of the principal is not possible. 27. In the present matter, nobody has a case that the agents whose authorities were impliedly revoked had any interest in the subject matter or have created any liability towards a third person. 28. The appointment of the second power-of-attorney holder came to the knowledge of the first power-of-attorney holder, and the appointment of the third power-of-attorney holder also came to the knowledge of the second power-of-attorney holder. As far as the present proceedings are concerned, the third party interested is the plaintiff. The plaintiff also has knowledge regarding the successive appointment of the powers-of-attorney. Therefore, as far as the principal- agent relation is concerned, the implied termination of the powers-of-attorney came to the knowledge of the prior power-of-attorney holders and the plaintiff – the third party. Therefore, the termination has taken effect as mandated in Sections 206 and 208 of the Contract Act. 29. There is no challenge to the validity of the power-of-attorney executed. As per Section 85 of the Evidence Act, the Court shall presume that every document purporting to be a power-of-attorney, and to have been executed before, and authenticated by, a Notary Public, or any Court, Judge, Magistrate was so executed and authenticated. 30. The contention raised by the learned counsel for the petitioner relying on Janki Vashdeo has no relevance to the subject matter. 30. The contention raised by the learned counsel for the petitioner relying on Janki Vashdeo has no relevance to the subject matter. The ratio in that decision relates to the admissibility of the evidence given by the power-of-attorney holder for and on behalf of the principal. 31. In the given case, the defendant appointed one Sri. R. Anilkumar as her power-of-attorney holder impliedly in the place of prior power-of-attorney holders, which fact came to the knowledge of prior power-of- attorney holders and the plaintiff-the third party. There is an implied revocation of the prior powers-of-attorney. Therefore, the revocation came into effect as provided in Section 208 of the Indian Contract Act. The trial Court accepted the power-of-attorney and permitted the person authorised to prosecute for and on behalf of the defendant. 32. The order impugned is not affected by any illegality or impropriety warranting interference by this Court under Article 227 of the Constitution. The Original Petition lacks merits. 33. Before parting with the judgment, this Court places its appreciation to Sri.M.R. Sasi, the learned Amicus Curiae, who has taken me to all the relevant legal provisions in this proceeding. The Original Petition stands dismissed.