Power of Attorney--Oral Revocation--Written Instrument Cannot Be Revoked or Modified by Parol Evidence and Revocation Must Be in Writing
A written power of attorney cannot be modified, altered, or revoked by oral statements. Where a right is transferred through a written document, revocation of that document must also be in writing and brought to the notice of the person in whose favour the right was conferred. Parol evidence is not admissible to substantiate an oral revocation of a written instrument. A sale deed executed by a power of attorney holder prior to receipt of written notice of revocation is valid, as the power of attorney remains operative until formally revoked in writing.
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