The Supreme Court in the matter of Bharat Sher Singh Kalsia Versus State Of Bihar & Anr., observed that if there is a repugnancy between the earlier and later clauses of a deed, whereby a later clause destroys altogether the obligation created by the earlier clause, then the later clause is to be rejected as repugnant to the earlier clause and the earlier clause prevails.

The Apex Court observed that if the earlier and later clauses of a deed cannot be reconciled then the earlier clause(s) would prevail over the later clause(s) when construing a Deed or a Contract.