In the Matter of Bhuley Singh Vs. Khazan Singh & Ors. RFA No.422/2011 The Hon’ble Delhi High Court said that nomenclature of a payment is not important and what is important is really the quantum of price which is paid. Only a nominal amount can be an earnest money, in as much as, the object of such a clause is to allow forfeiture of that amount to a nominal extent.