NARANBHAI DAYABHAI PATEL & ANR. vs SULEMAN ISUBJI DADABHAI

The Supreme Court held that under Section 32 of the Bombay Tenancy & Agricultural Lands Act, 1948, tenants become deemed purchasers as of April 1, 1957, thereby divesting the landholder of ownership rights. The Court ruled that the creation of a trust by the landholder after this date was invalid, as the land had already vested in the tenants. The appeal was allowed, affirming the lower court's decision that the trust was not legally valid due to the statutory purchase by the tenants.