Court case(1889) ILR 13 Mad 214

A thirteen-year-old Hindu girl lost her husband. His relatives wanted her to adopt a boy of their choice. When she refused, they prevented the removal of her husband's corpse from the house for cremation until she agreed to the adoption. Under that pressure she gave her consent and the adoption was carried out. She later challenged the adoption as one to which she had never freely consented.

The Madras High Court held that obstructing the removal and cremation of the dead body was an act forbidden by the Indian Penal Code (the offence of indignity to a human corpse). Using that act to make the widow agree was "coercion" under s. 15, and the adoption, made under such coercion, was not binding on her. The court treated the consent to adoption like consent to an agreement and applied the statutory definition.