STATE OF ORISSA vs NITYANAND SATPATHY

The Supreme Court held that under Section 5 of the Orissa Estates Abolition Act, 1951, non-agricultural land vests in the State, and thus the settlement of such land to the sons of Manindra Chandra Sinha was invalid. The Court found that the Board of Revenue correctly revoked the settlement based on the land being Anabadi land, which had already vested in the State. The High Court's decision to set aside the Board's order was overturned, affirming the State's position.