BIRSA MUNDA vs CHANDO KUMARI .

The Supreme Court addressed an appeal concerning the interpretation of Section 46(4)(a) of the Chhotanagpur Tenancy Act, where the appellant, a tribal, sought possession of land surrendered by his father. The Court held that the Commissioner correctly found the appellant's possession within 12 years, and emphasized that the term 'transfer' in Section 71(a) of the Act should be interpreted liberally to protect Scheduled Tribe members. The Court set aside the High Court's decision that relied on an earlier Full Bench ruling, affirming the appellant's right to reclaim possession.