8. There cannot be any doubt that substitute service shall be a sufficient service in ordinary circumstances. But before that, the Court must be careful to see that conditions enumerated in Order V Rule 20(1) have been strictly complied with. In most of the cases, publications by an advertisement in a newspaper would be a futile exercise because such publications are being made in daily newspapers having no wide circulation in the area, in which the defendant is actually residing or earlier resided. Moreover, the illiterate or ignorant persons may not have access to the newspapers. It is a ground reality that only few educated persons subscribe daily news papers and most of the readers are not bothered about the Court notices. Therefore, unless the Court is satisfied that the defendant is keeping out of the way for the purpose of avoiding service or that the summons cannot be served in the ordinary way, the Courts should not order substitute service by way of paper publication. It appears that after exhausting all other modes of service as contemplated under Order V Rule 20(1) C.P.C, the Court should resort to service by an advertisement in a news paper under Order V Rule 20(1A) C.P.C.
