SITARAM JIVYABHAI GAVALI vs RAMJIBHAI PETIYABHAI MAHALA & ORS.

The Supreme Court examined the applicability of Article 102(1)(a) of the Constitution regarding disqualifications for membership of Parliament, specifically addressing whether the appellant, a temporary government servant, held an 'office of profit' at the time of filing his nomination. The Court held that the doctrine of relation forward applies, determining that the appellant's resignation was effective from the date he tendered it, thus allowing him to contest the election. The Court reversed the lower court's decision, validating the appellant's election as he was not disqualified under the relevant provisions.