BHAGWAN DAS vs SARDAR ATMA SINGH

The Supreme Court addressed the applicability of Section 264 of the Madhya Pradesh Land Revenue Code, 1959, in determining the Bhumiswami rights of the appellants, who claimed possession of land against the respondent, a former owner. The Court held that since Idnani had been granted a permanent sanad prior to the enactment of the Code, the appellants acquired Bhumiswami rights under Section 190 of the Code, thus rendering the respondent's claim for possession invalid. The appeal was allowed, affirming the appellants' rights to the land.