STATE OF KERALA AND ORS. vs PHILOMINA, ETC. ETC. & ORS.

The Supreme Court interpreted Section 84 of the Kerala Land Reforms Act, 1963, which invalidates all voluntary land transfers post-September 15, 1963. The Court held that transfers of kayal lands made between September 15, 1963, and January 1, 1970, were valid due to an exemption that was not retroactively applied until the amendment came into force. Additionally, the Court ruled that the exemption for transfers made out of natural love and affection was removed by the 1972 amendment, rendering such transfers invalid if made after January 1, 1970.