T. V. V. NARASIMHAM AND OTHERS vs THE STATE OF ORISSA

The Supreme Court interpreted Section 3(2)(d) of the Madras Estates Land Act, 1908, clarifying that 'recognition' requires an explicit acknowledgment of title by the Government, not mere inaction. The Court held that while the Government's 1919 order recognized the title of certain inamdars, it erred in concluding that inaction constituted recognition for others. The judgment of the Orissa High Court was thus partially overturned, affirming the need for unequivocal acts to establish recognition under the statute.