KALANKA DEVI SANSTHAN vs MAHARASHTRA REVENUE TRIBUNAL, NAGPURl & ORS.

The Supreme Court held that under Section 2(12) Explanation I of the Bombay Tenancy and Agricultural Lands (Vidarbha Region) Act, 1958, a private religious trust cannot claim possession of agricultural land for personal cultivation as it does not qualify as a 'person' capable of personal cultivation. The Court emphasized that cultivation must be by natural persons, rejecting the argument that an idol or trust could be deemed to have a physical or mental disability. The appeal was dismissed, affirming the lower courts' decisions that the provisions of the Act were not violative of Articles 14 and 19(1)(f) of the Constitution due to the immunity provided by Article 31(A).