SAKHARAM BAPUSAHEB NARAYAN SANAS AND ANOTHER vs MANIKCHAND MOTICHAND SHAH AND ANOTHER

The Supreme Court held that the rights of protected tenants under Section 3A(1) of the Bombay Tenancy Act, 1939, were preserved despite the repeal of the Act by the Bombay Tenancy and Agricultural Lands Act, 1948. The Court interpreted Section 88(1)(c) and Section 89(2)(b) of the 1948 Act, concluding that these provisions are prospective and do not confiscate existing rights of tenants. The Court affirmed that legal proceedings regarding such rights should continue under the provisions of the repealed Act, thus upholding the appellants' status as protected tenants.