MULAMCHAND vs STATE OF MADHYA PRADESH

The Supreme Court held that the right to collect forest produce was a proprietary right that vested in the State under Section 4(1)(a) of the Madhya Pradesh Abolition of Proprietary Rights (Estates, Mahals, Alienated Lands) Act, 1950. The Court overruled the contrary view in Chhotabhai Jethabhai Patel & Co.’s case, affirming that the contract with the appellant was void due to non-compliance with Article 299 of the Constitution. However, the claim for refund of Rs. 10,000 was denied as the appellant did not meet the conditions of Section 70 of the Indian Contract Act regarding restitution.