KARIMBIL KUNHIKOMAN vs STATE OF KERALA

The Supreme Court upheld the validity of the Kerala Agrarian Relations Act, 1961, stating that the Act did not lapse despite being passed by a dissolved assembly and re-passed by a new one. However, it struck down certain provisions as violative of Article 14 of the Constitution, particularly those relating to plantations, asserting that the Act's distinctions lacked intelligible differentia. The Court ruled that ryotwari lands transferred from Madras are not 'estates' under Article 31A, thus the Act is not protected from constitutional scrutiny. Consequently, the entire Act was declared unconstitutional due to its violations of Articles 14, 19, and 31.