KUNJUKUTTY SAHIB ETC. ETC. vs STATE OF KERALA & ANR.

The Supreme Court examined the validity of the Kerala Land Reforms (Amendment) Act, 1969, which was not included in the Ninth Schedule and thus not protected under Article 31-B. The Court held that arrears of rent under Section 42 do not constitute an interest in land as defined in Article 31-A, and therefore Section 73, which provides for liquidation of such arrears, is not protected. The Court also addressed the validity of Sections 45-A and the explanation to Section 85(1), concluding that the amended Act's reduction of ceiling limits without compensation violates constitutional provisions.