UTTAM CHAND vs STATE OF MAHARASHTRA & ANR.

The Supreme Court held that under the Maharashtra Agricultural Lands (Ceiling on Holdings) Act, 1961, land transferred prior to 4-8-1959 is exempt from ceiling limits. The Court restored the Deputy Collector's order, finding no evidence of collusion in the transfers made by the appellant to his adopted son and by the adopted son to his mother. The High Court's presumption of collusion was deemed unjustified as it lacked a factual basis, thus reinforcing the principle that self-acquired property cannot be clubbed with family property under the Act.