ANANGA BIJOY MITTRA vs TATA IRON & STEEL CO., LTD.

The Supreme Court held that the lease in question was not for agricultural or horticultural purposes under the Chotanagpur Tenancy Act, 1908, specifically sections 4(2) and 6. The Court emphasized that the application for lease indicated a monthly tenancy and an agreement to abide by house building rules, which negated the claim of the appellant being a raiyat. Consequently, the Court upheld the High Court's decision to order eviction of the appellant from the land in Jamshedpur.