UNION TERRITORY OF GOA, DAMAN AND DIU AND ANR. vs LAKSHMIBAI NARAYAN PATIL ETC. ETC.ANDSMT. LAKSHMI BAI PATIL

The Supreme Court held that the Goa, Daman and Diu Agricultural Tenancy (5th Amendment) Act, 1976, which omitted provisions for ceiling on land holdings, is constitutionally valid under Article 31A. The Court clarified that while statutes with ceiling provisions are typically associated with agrarian reform, the absence of such provisions does not automatically disqualify a law from being considered agrarian reform. The Court dismissed the writ petition challenging the Amendment Act, affirming that it can still qualify for protection under Article 31A if it serves the purpose of agrarian reform.