FINANCIAL COMMISSIONER, HARYANA AND OTHERS vs KELA DEVI AND ANOTHER

The Supreme Court held that under Section 10A(a) of the Punjab Security of Land Tenures Act, 1953, the mere allotment of surplus land to other tenants does not constitute 'utilization' unless the allottee has taken possession. The Court clarified that an order of allotment is only an initial step and does not complete the process of utilization, as possession and execution of necessary documents are required. The appeal was dismissed, affirming that the heirs could contest the surplus area after inheriting the land, as the process of utilization had not been completed.