BYRAMJEE JEEJEEBHOY (P) LTD. vs STATE OF MAHARASHTRA

The Supreme Court held that the grant dated September 22, 1847, was not a lease under Section 2(d) of the Salsette Estates (Land Revenue Exemption Abolition) Act, XLVII of 1951, as it transferred ownership rights rather than mere enjoyment rights. The Court determined that the grant was not a 'farm' since the grantee was not liable to pay revenue. It affirmed that the villages were held under an agreement from the State of Bombay, fulfilling the conditions of the Act. The judgment clarified that exemptions under special contracts or grants are preserved under Clause 3 of Section 3 of the Act.