STATE OF BIHAR AND ANOTHER vs UMESH JHA

The Supreme Court upheld the constitutional validity of Section 4(h) of the Bihar Land Reforms Act, 1950, as amended by the Bihar Land Reforms (Amendment) Act, 1959, which allows the Collector to annul anticipatory land transfers aimed at defeating the Act's objectives, affirming its protection under Article 31A of the Constitution. The Court clarified that the second proviso to Section 4(h) is not retrospective, requiring prior sanction for annulments made before the Amending Act's enactment, while subsequent annulments necessitate confirmation from the State Government. The decision in Thakur Raghubir Singh v. State of Ajmer was applied to support this interpretation.