A division bench of the Apex Court held as follows, with respect to what a GPA-holder can do and not.

Order III, Rules 1 and 2 CPC, empowers the holder of power of attorney to “act” on behalf of the principal. In our view the word “acts” employed in Order III, Rules 1 and 2 CPC, confines only in respect of “acts” done by the power of attorney holder in exercise of power granted by the instrument. The term “acts” would not include deposing in place and instead of the principal. In other words, if the power of attorney holder has rendered some “acts” in pursuance to power of attorney, he may depose for the principal in respect of such acts, but he cannot depose for the principal for the acts done by the principal and not by him. Similarly, he cannot depose for the principal in respect of the matter which only the principal can have a personal knowledge and in respect of which the principal is entitled to be cross-examined.

Citations: [AIR 2005 SUPREME COURT 439], [2005 (2) SCC 217, 2004 AIR SCW 7064, (2007) 2 NIJ 395, 2005 (2) SRJ 281, (2004) 10 JT 264 (SC), (2005) 3 CTC 128 (SC), (2005) 3 MAD LJ 109], [2004 (10) JT 264, (2005) 1 CLR 737 (SC)], [(2005) 3 JCR 175 (SC), 2004 (10) SCALE 244, 2005 (2) ALL CJ 924, 2004 (7) SLT 441, (2005) ILR (KANT) 729, (2005) 1 ALL WC 138, (2004) 63 CORLA 174], [(2005) 1 RECCIVR 240, (2005) 3 MAD LW 403, (2004) 10 SCALE 244, (2005) 1 SCJ 520, (2005) 2 CIVILCOURTC 324, (2005) 2 LANDLR 585, (2005) 98 REVDEC 371, (2005) 3 ANDHLD 43, (2005) 3 SUPREME 275, (2005) 1 WLC(SC)CVL 245, (2005) 1 CAL HN 175, (2005) 123 COMCAS 154, (2005) 1 MAH LJ 1170, (2005) 1 MPLJ 421, (2005) 2 PUN LR 1, (2005) 1 KCCR 227, (2005) 58 ALL LR 440], [(2005) 2 ANDH LT 57, (2005) 2 KER LT 265, (2005) 58 ALL LR 610, (2005) 1 ALL RENTCAS 409, (2005) 3 CIVLJ 775, (2005) 2 CURCC 61, (2005) 1 ALL WC 831, (2005) 1 BANKCLR 438], [(2005) 3 BOM CR 846]

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