LAXMINARAYAN DIPCHAND MAHESHWARI & ORS. vs MAHARASHTRA REVENUE TRIBUNAL & ORS.

The Supreme Court held that Section 49A of the Bombay Tenancy and Agricultural Lands (Vidarbha Region) Act, 1958 does not apply as it pertains to land not transferred under Section 46 or purchased under Sections 41 and 50. The Court affirmed that tenants became full owners of the land by operation of law under Section 46, effective from April 1, 1961, and this statutory vesting cannot be undone without explicit provision in the Act. The Court found no violation of Articles 14 and 19(1)(f) of the Constitution, confirming the validity of Section 46.