RAJA BAHADUR KAMAKSHYA NARAINSINGH AND OTHERS vs THE COLLECTOR AND DEPUTY COMMISSIONER OF HAZARIBAGH AN

The Supreme Court held that under the Bihar Land Reforms Act, 1950, the estate of the petitioner vested in the State either by notification under Section 3(1) or by virtue of Section 4, making the distinction irrelevant. The Court clarified that the definition of 'estate' includes buildings as per Sections 4, 5, and 7, despite the term 'land' being used. It ruled that Section 4(h) is valid and imposes conditions on transfers made after January 1, 1946, regarding the use of buildings for rent collection, thus affirming the State's right to vest properties in itself.