SAHADU BALA BOTRE (DEAD) BY LRS.AND ANR. vs NAMDEO BAPUJI KERALA (DEAD) BY LRS.AND ORS.

The Supreme Court examined the interpretation of the second proviso to Section 84A of the Bombay Tenancy and Agricultural Land Act, 1948, in the context of a sale deed validation application. The Court held that the validation of a transfer made in contravention of Sections 63 or 64 is contingent upon the tenant's eviction status and the payment of a penalty. The Court affirmed the High Court's interpretation, concluding that the transfer could not be validated due to the tenant's actual possession and the conditions outlined in the second proviso.