K.N. Farms Industries (Pvt.) Ltd vs State Of Bihar & Ors

The Supreme Court held that a tank falls within the definition of 'land' under Section 2(f) of the Bihar Land Reforms (Fixation of Ceiling Area and Acquisition of Surplus Land) Act, 1961, as it includes land perennially submerged under water. The Court affirmed the lower courts' decisions that the legislative intent was to include tanks used for agricultural purposes within this definition. Consequently, the appeal challenging the inclusion of tank area in surplus land determination was dismissed, upholding the interpretation of 'land' as encompassing such tanks.