BHIKOBA SHANKAR DHUMAL (DEAD) BY LRS. & ORS. vs MOHAN LAL PUNCHAND TATHED & ORS.

The Supreme Court interpreted the Maharashtra Agricultural Lands (Ceiling on Holdings) Act, 1961, particularly Section 21, clarifying that the title to surplus land remains with the holder until possession is taken post-notification. The Court held that the heirs of a deceased landholder are entitled to the entire holding until such notification is published, thereby establishing that proceedings can be dropped if the title has not been divested. The appeal by the former landlords was dismissed, affirming the decision of the Special Deputy Collector to drop proceedings against the heirs of Bhikoba.