STATE OF MADRAS vs P. GOVINDARAJULU NAIDU

The Supreme Court held that the village of Mothirambedu, held under a permanent under-tenure, qualifies as an estate under Section 3(2)(e) of the Madras Estates Land Act, 1908, and is therefore excluded from the definition of 'zamin estate' under Section 2(3) of the Madras Estates (Abolition and Conversion into Ryotwari) Act, 1948. The Court ruled that the government's notification declaring it a zamin estate was void, emphasizing that the reversionary interest's holder is crucial in determining the nature of tenure. The High Court's decision was upheld, affirming the distinction between zamin and under-tenure for compensation purposes.