SURAJ SINGH vs STATE OF M.P. .

The Supreme Court examined the applicability of the Adhiniyam regarding the definition of 'holder of agricultural land' under Section 2(c) and the protections afforded under Section 5. The Court held that the appellants, who held 1.32 and 2.57 hectares of agricultural land, qualified as 'holders of agricultural land' and were entitled to protection under the Adhiniyam, despite the lower courts' findings to the contrary. The judgment emphasized that the provisions of the Adhiniyam override other considerations, and the appeals were allowed, reversing the decisions of the Collector and the High Court.