The Theory of Past Results, based on equity principle, was established in England and was subsequently added to the Transfer of Property Act, 1882 via the Amendment Act of 1929. In contract law ( e.g. a contract for sale), no rights are transferred to another before the transaction is complete But if a person performs his or her part after entering into a contract or performs some act to further the contract, he or she is entitled to compensation or payment if the other party drags its feet. Section 53A provides that if a person enters into an agreement with another person and permits the other person to act on behalf of the contract, that person shall, in turn, create equity that cannot be resisted on the grounds of lack of formality in the evidence or contract of the transfer. Thus, if the contract has not been registered or concluded in a specified manner, the transferor can still not object to the transferee or to anyone who claims it. Nevertheless, the act will not be unsigned or unmarked. Everything in this section affects the rights of the transferee for consideration even though he did not have notice of the contract of partial results.
For example, A entered into the contract with B to sell his car for $1000. A accepts the advance of $100 from B. A gave his car to B for use. After some time, B was ready to pay the rest of the amount but A refuses to take and asked B to return his car. Here, B was ready to perform his part of the contract and hence B can bring a case against A for the specific performance of the contract.
In compliance with the rule, a sale of immovable property worth over Rs. 100 must be registered. This was assumed, however, that strict enforcement could lead to extreme hardships, particularly when one party had already done its part in the trust that the other party would honour the agreement. Unless no such registration or other formalities have occurred, the theory of component success shall apply. If the transferee takes possession of the property, the transferee cannot be evicted because of an unregistered contract.
The section is both a defence and a right that helps protect the possession from any challenge. It is attempting to prevent fraud on the mere basis of ineffective transfer-proof. The section does not confer a title upon the transferee in possession but it imposes a statutory bar on the transferor.
Walsh vs. Longsdale and Maddison v. Alderson are the two most important cases which helped in developing the doctrine of part performance in England. In India, this doctrine has been enacted with few amendments.