MOTIPUR ZAMINDARI CO. LTD. vs THE STATE OF BIHAR AND ANOTHER.RAJA JANKINATH ROY AND NARE

The Supreme Court interpreted the definitions of 'proprietor' and 'tenure-holder' in Sections 2(o) and 2(r) of the Bihar Land Reforms Act, 1950, concluding that the term 'person' includes companies incorporated under the Indian Companies Act, 1913. The Court held that this inclusion is essential for fulfilling the Act's objectives, thereby affirming the applicability of the Act to corporate entities. The judgment distinguished the case from Pharmaceutical Society v. The London and Provincial Supply Association, Limited (1880) 5 App. Cas. 857.