BHAGWAN DAS vs THE STATE OF PUNJAB

The Supreme Court held that under the Punjab Security of Land Tenures Act, 1953, the status of a landowner as a 'small landowner' must be evaluated based on the land held at the commencement of the Act, specifically under Section 9(1)(i). The Court clarified that improvements in land value or re-allotment do not alter this status if no additional land is acquired post-commencement. The High Court's ruling that status should be determined at the time of eviction application was overturned, affirming the appellant's status as a small landowner.