JYOTISH THAKUR AND OTHERS vs TARAKANTJHA AND OTHERS

The Supreme Court held that the raiyati interest of a landowner does not merge with the proprietary interest upon acquiring the superior landlord's interest, as established under Section 27 of Regulation III of 1872. The Court clarified that the doctrine of merger does not apply to raiyati holders in the Santhal Parganas, allowing the raiyat to retain his rights despite acquiring the superior interest. Consequently, the plaintiffs were entitled to relief in the civil court, as the raiyati interest remained distinct and was not transferred by the sale deed dated May 15, 1935.