ASHARAFI SINGH vs KAPILDEO RAI(DEAD) AND OTHERS

The Supreme Court upheld the applicability of the Bihar Consolidation of Holdings and Prevention of Fragmentation Act, 1956, specifically Section 2(9) which defines 'land' broadly to include various types of land beyond strictly agricultural land. The Court found that the appellant's purchase of land after the notification under Section 5 of the Act was invalid as it required prior sanction from the consolidation officer. The appeal was dismissed, affirming the High Court's decision without costs.