PATEL CHUNIBHAI DAJIBHAI ETC. vs NARAYANRAO KHANDERAO JAMBEKAR ANDANOTHER

The Supreme Court interpreted Section 32 of the Bombay Tenancy and Agricultural Lands Act, 1948, holding that tenants could only be deemed purchasers of the land if no eviction application under Section 14 or Section 31 was pending on April 1, 1957. The Court clarified that the conditions in Section 32(1)(b)(i), (ii), and (iii) are not alternative but conjunctive, meaning that pending applications prevent the acquisition of ownership. The Court upheld the High Court's decision that the appellants did not acquire rights under the amended Section 32 due to the pending eviction application, thus ruling in favor of the respondent-landlord.