Kunj Behari Lal Butail And Ors vs State Of Himachal Pradesh And Ors

The Supreme Court examined the constitutional validity of an amendment to the Himachal Pradesh Ceiling on Land Holdings Rules, 1973, and a circular issued by the Registrar regarding the sale of land exempted from the Act. The Court held that the amendment, which restricted the transfer of land subservient to tea plantations without government permission, was valid and within the legislative framework of the Himachal Pradesh Ceiling on Land Holdings Act, 1972, specifically under Section 26. The Court affirmed that the rules were enacted to prevent circumvention of the Act's provisions, thereby upholding the government's authority to regulate land use in the interest of agricultural policy.