Supreme Court Clarifies Tenant Purchase Rights Under Maharashtra Tenancy Act: Vasant Ganpat Padave vs Anant Mahadev Sawant (2019) INSC 741 (18 September 2019)

Introduction

Date of the Judgment: 18 September 2019

Citation: (2019) INSC 741

Judges: R.F. Nariman, J., R. Subhash Reddy, J., and Surya Kant, J. (authored by R.F. Nariman, J.)

Can a tenant’s right to purchase agricultural land be nullified simply because they were unaware of their landlord’s death or the end of a disability? The Supreme Court of India recently addressed this critical question in a case concerning the Maharashtra Tenancy and Agricultural Lands Act, 1948. This judgment clarifies the rights of tenants, particularly when landlords have disabilities such as being a widow, minor, or having a mental or physical disability. The court examined whether the tenant’s right to purchase land is affected if they are unaware of the cessation of such disabilities.

Case Background

The case revolves around a piece of agricultural land in Ratnagiri, Maharashtra. The original landlord, Balwant Sawant, passed away in 1950, leaving his widow, Indirabai Balwant Sawant, as the owner. The tenants, predecessors of the appellants, were cultivating the land before 1956-1957. Under the Bombay Tenancy and Agricultural Lands Act, 1948, as amended in 1957, tenants were deemed to have purchased the land they cultivated from their landlords on April 1, 1957 (“Tillers’ Day”).

However, because Indirabai was a widow, the proceedings to declare the tenants as purchasers were suspended. Indirabai executed a will in 1975 in favor of Anant Mahadev Sawant (Respondent 1). She died in 1999, and Respondent 1’s name was recorded in the revenue records in 2000, without notice to the tenants.

In 2008, the tenants, upon learning of Indirabai’s death and the mutation in favor of Respondent 1, applied to the Additional Tahsildar for fixing the purchase price under Section 32-G of the Act. The Additional Tahsildar allowed the application in 2011. However, the Sub-Divisional Officer reversed this decision in 2013, stating that the tenants had lost their right to purchase because they did not issue notice within the time prescribed under Section 32-F of the Act.

The Maharashtra Revenue Tribunal upheld the Sub-Divisional Officer’s order in 2013. The High Court dismissed the tenants’ writ petitions in 2014, leading to the current appeals before the Supreme Court. The core issue is whether the tenants lost their right to purchase due to their failure to issue notice within one year of the landlady’s death, despite not being informed of her death.

Timeline:

Course of Proceedings

The Additional Tahsildar initially ruled in favor of the tenants in 2011, allowing their application to fix the purchase price. However, this decision was overturned by the Sub-Divisional Officer in 2013, who held that the tenants had lost their right to purchase the land because they failed to issue a notice under Section 32-F within the prescribed time. The Maharashtra Revenue Tribunal upheld this decision, stating that the tenants were legally obligated to express their desire to purchase within the stipulated time under Section 32-F, which they had not done.

The High Court dismissed the writ petitions filed by the tenants, agreeing with the lower authorities that the tenants had lost their right to purchase due to the delay in issuing the notice. The High Court’s decision was based on previous judgments of the Supreme Court which held that the tenant’s right to purchase is lost if the tenant does not exercise the right within the prescribed period under Section 32-F.

A Division Bench of the Supreme Court, while hearing the appeals, noted that previous judgments of the Court did not consider the 1969 amendment to Section 32-F(1)(a) which mandates intimation by a minor landlord after attaining majority. The Division Bench felt that the same object should be extended to other categories of disabled landlords, i.e., widows and persons with disabilities. The Division Bench referred the matter to a larger bench for reconsideration of the previous judgments, as it felt that the tenant’s right to purchase should not be defeated if the tenant is unaware of the cessation of the landlord’s disability.

Legal Framework

The judgment primarily revolves around the interpretation of the Maharashtra Tenancy and Agricultural Lands Act, 1948, specifically the following sections:

• Section 2(6) of the Maharashtra Tenancy and Agricultural Lands Act, 1948, defines “to cultivate personally” and includes an explanation that a widow, minor, or person with a disability is deemed to cultivate land personally if it is cultivated by servants, hired labor, or tenants.

  “2. Definitions.-In this Act, unless there is anything repugnant in the subject or context,
  xxx xxx xxx
  (6) “to cultivate personally”…
  Explanation I – A widow or a minor, or a person who is
  subject to physical or mental disability, or a serving
  member of the armed forces shall be deemed to cultivate
  the land personally if such land is cultivated by servants, or
  by hired labour, or through tenants.”

• Section 2(8) of the Maharashtra Tenancy and Agricultural Lands Act, 1948, defines “land” as land used for agricultural purposes.
• Section 2(18) of the Maharashtra Tenancy and Agricultural Lands Act, 1948, defines “tenant” to include deemed tenants, protected tenants, and permanent tenants.
• Section 4 of the Maharashtra Tenancy and Agricultural Lands Act, 1948, states that a person lawfully cultivating land belonging to another is deemed a tenant if the owner does not cultivate it personally.
• Section 4-B of the Maharashtra Tenancy and Agricultural Lands Act, 1948, states that tenancies cannot be terminated merely because the fixed period of an agreement has expired.
• Section 31 of the Maharashtra Tenancy and Agricultural Lands Act, 1948, outlines a landlord’s right to terminate a tenancy for personal cultivation. It allows landlords who are minors, widows, or persons with disabilities to terminate tenancies within one year of their disability ceasing.

  “31. Landlord’s right to terminate tenancy for personal
  cultivation and non-agricultural purpose .—
  (1) Notwithstanding anything contained in Sections 14 and
  30 but subject to Sections 31-A to 31-D (both inclusive), a
  landlord (not being a landlord within the meaning of
  Chapter III-AA) may, after giving notice and making an
  application for possession as provided in sub-section (2),
  terminate the tenancy of any land (except a permanent
  tenancy), if the landlord bona fide requires the land for any
  of the following purposes:-
  (a) for cultivating personally, or
  (b) for any non-agricultural purpose.
  (2) The notice required to be given under sub-section (1)
  shall be in writing, shall state the purpose for which the
  landlord requires the land and shall be served on the
  tenant on or before the 31st day of December, 1956. A
  copy of such notice shall, at the same time, be sent to the
  Mamlatdar. An application for possession under Section 29
  shall be made to the Mamlatdar on or before the 31st day
  of March, 1957.
  (3) Where a landlord is a minor, or a widow, or a person
  subject to mental or physical disability then such notice
  may be given and an application for possession under
  Section 29 may be made,—
  (i) by the minor within one year from the date on which he
  attains majority;
  (ii) by the successor-in-title of a widow within one year from
  the date on which her interest in the land ceases to exist;
  (iii) within one year from the date on which mental or
  physical disability ceases to exist; and
  (iv)***
  Provided that where a person of such category is a
  member of a joint family, the provisions of this sub-section
  shall not apply if at least one member of the joint family is
  outside the categories mentioned in this sub-section unless
  before the 31st day of March, 1958 the share of such
  person in the joint family has been separated by metes and
  bounds and the Mamlatdar on inquiry is satisfied that the
  share of such person in the land is separated, having
  regard to the area, assessment, classification and value of
  the land, in the same proportion as the share of that person
  in the entire joint family property, and not in a large
  proportion.”

• Section 32 of the Maharashtra Tenancy and Agricultural Lands Act, 1948, states that on “Tillers’ Day” (April 1, 1957), every tenant is deemed to have purchased the land they cultivate, subject to other provisions.

  “32. Tenants deemed to have purchased land on tillers’
  day –
  (1) On the first day of April 1957 (hereinafter referred to as
  “the tillers day”) every tenant shall, subject to the other
  provisions of this section and the provisions of the next
  succeeding sections, be deemed to have purchased from
  his landlord, free of all encumbrances subsisting thereon
  on the said day, the land held by him as tenant, if, –
  (a)Such tenant is a permanent tenant thereof and
  cultivates land personally;
  (b)Such tenant is not a permanent tenant but cultivates
  the land leased personally; and
  (i)the landlord has not given notice of termination
  of his tenancy under Section 31; or
  (ii)notice has been given under Section 31, but the
  landlord has not applied to the Mamlatdar on or
  before the 31st day of March, 1957 under Section
  29 for obtaining possession of the land; or
  (iii)the landlord has not terminated this tenancy on
  any of the grounds specified in Section 14, or
  has so terminated the tenancy but has not
  applied to the Mamlatdar on or before the 31st
  day of March, 1957 under Section 29 for
  obtaining possession of the land:
  Provided that if an application made by the landlord under
  Section 29 for obtaining possession of the land has been
  rejected by the Mamlatdar or by the Collector in appeal or
  in revision by the Maharashtra Revenue Tribunal under the
  provisions of this Act, the tenant shall be deemed to have
  purchased the land on the date on which the final order of
  rejection is passed. The date on which the final order of
  rejection is passed is hereinafter referred to as “the
  postponed date”.
  Provided further that the tenant of a landlord who is entitled
  to the benefit of the proviso to sub-section (3) of Section 31
  shall be deemed to have purchased the land on the 1st day
  of April 1958, if no separation of his share has been
  effected before the date mentioned in that proviso.
  (1A) (a) Where a tenant, on account of his eviction from
  the land by the landlord, before the 1st day of April, 1957, is
  not in possession of the land on the said date but has
  made or makes an application for possession of the land
  under sub-section (1) of Section 29 within the period
  specified in that sub-section, then if the application is
  allowed by the Mamlatdar, or as the case may be, in
  appeal by the Collector or in revision by the Maharashtra
  Revenue Tribunal, he shall be deemed to have purchased
  the land on the date on which the final order allowing the
  application is passed.
  (b) Where such tenant has not made an application, for
  possession within the period specified in sub-section (1) of
  Section 29 or the application made by him is finally rejected
  under this Act, and the land is held by any other person as
  tenant on the expiry of the said period or on the date of the
  final rejection of the application, such other person shall be
  deemed to have purchased the land on the date of the
  expiry of the said period or as the case may be, on the date
  of the final rejection of the application.
  (1B) Where a tenant who was in possession on the
  appointed day and who on account of his being
  dispossessed before the 1st day of April 1957 otherwise
  than in the manner and by an order of the Tahsildar as
  provided in Section 29, is not in possession of the land on
  the said date and the land is in the possession of the
  landlord or his successor-in-interest on the 31st day of July
  1969 and the land is not put to a non-agricultural use on or
  before the last mentioned date, then, the Tahsildar shall,
  notwithstanding anything contained in the said Section 29,
  either suo motu or on the application of the tenant, hold an
  inquiry and direct that such land shall be taken from the
  possession of the landlord or, as the case may be, his
  successor-in-interest, and shall be restored to the tenant;
  and thereafter, the provisions of this Section and Section
  32-A to 32-R(both inclusive) shall, in so far as they may be
  applicable, apply thereto, subject to the modification that
  the tenant shall be deemed to have purchased the land on
  the date on which the land is restored to him.
  Provided that, the tenant shall be entitled to restoration of
  the land under this sub-section only if he undertakes to
  cultivate the land personally and of so much thereof as
  together with the other land held by him as owner or tenant
  shall not exceed the ceiling area.
  Explanation – In this sub-section, “successor-in-interest”
  means a person who acquires the interest by testamentary
  disposition or devolution on death.”

• Section 32-F of the Maharashtra Tenancy and Agricultural Lands Act, 1948, provides the right of a tenant to purchase land where the landlord is a minor, widow, or person with a disability. It originally required the tenant to exercise this right within one year of the landlord’s disability ceasing. The 1969 amendment added that a minor landlord must send intimation to the tenant upon attaining majority, to enable the tenant to exercise the right of purchase.

  “32-F. Right of tenant to purchase where landlord is
  minor, etc.—
  (1)Notwithstanding anything contained in the preceding
  sections,—
  (a) where the landlord is a minor, or a widow, or a person
  subject to any mental or physical disability, the tenant shall
  have the right to purchase such land under Section 32
  within one year from the expiry of the period during which
  such landlord is entitled to terminate the tenancy under
  Section 31 and for enabling the tenant to exercise the right
  of purchase, the landlord shall send an intimation to the
  tenant of the fact that he has attained majority, before the
  expiry of the period during which such landlord is entitled to
  terminate the tenancy under Section 31:
  Provided that where a person of such category is a
  member of a joint family, the provisions of this sub-section
  shall not apply if at least one member of the joint family is
  outside the categories mentioned in this sub-section unless
  before the 31st day of March 1958 the share of such
  person in the joint family has been separated by metes and
  bounds and the Mamlatdar on inquiry is satisfied that the
  share of such person in the land is separated, having
  regard to the area, assessment, classification and value of
  the land, in the same proportion as the share of that person
  in the entire joint family property and not in a larger
  proportion.
  (b) where the tenant is a minor, or a widow, or a person
  subject to any mental or physical disability or a serving
  member of the armed forces, then subject to the provisions
  of clause (a), the right to purchase land under Section 32
  may be exercised, –
  (i)By the minor within one year, from the date on
  which he attains majority;
  (ii)By the successor-in-title of the widow within one
  year from the date on which her interest in the
  land ceases to exist;
  (iii)Within one year from the date on which the
  mental or physical disability of the tenant ceases
  to exist;
  (iv)Within one year from the date on which the
  tenant ceases to be a serving member of the
  armed forces:
  Provided that where a person of such category is a
  member of a joint family, the provisions of this sub-section
  shall not apply if at least one member of the joint family is
  outside the categories mentioned in this sub-section unless
  before the 31st day of March, 1958 the share of such
  person in the joint family has been separated by metes and
  bounds and the Mamlatdar on inquiry is satisfied that the
  share of such person in the land is separated, having
  regard to the area, assessment, classification and value of
  the land, in the same proportion as the share of that person
  in the entire joint family property, and not in a larger
  proportion.
  (1-A) A tenant desirous of exercising the right conferred on
  him under sub-section (1) shall give an intimation in that
  behalf to the landlord and the Tribunal in the prescribed
  manner within the period specified in that sub-section:
  Provided that, if a tenant holding land from a landlord (who
  was a minor and has attained majority before the
  commencement of the Tenancy and Agricultural Lands
  Laws (Amendment) Act, 1969) has not given intimation as
  required by this sub-section but being in possession of the
  land on such commencement is desirous of exercising the
  right conferred upon him under sub-section (1), he may
  give such intimation within a period of two years from the
  commencement of that Act.
  (2) The provisions of Sections 32 to 32-E (both inclusive)
  and Sections 32-G to 32-R (both inclusive) shall, so far as
  may be applicable, apply to such purchase”

• Section 32-G of the Maharashtra Tenancy and Agricultural Lands Act, 1948, requires the Tribunal to issue notice to tenants and landlords to determine the price of the land to be paid by the tenant.

  “32G. Tribunal to issue notice and determine price of
  land to be paid by tenants. –
  (1) As soon as may be after the tillers’ day the Tribunal
  shall publish or cause to be published a public notice in the
  prescribed form in each village within its jurisdiction calling
  upon, –
  (a) all tenants who under Section 32 are deemed to have
  purchased the lands,
  (b) all landlords of such lands, and
  (c) all other persons interested therein,
  to appear before it on the date specified in the notice. The
  Tribunal shall issue a notice individually to each such
  tenant, landlord and also, as far as practicable, other
  person calling upon each of them to appear before it on the
  date specified in the public notice.
  (2) The Tribunal shall record in the prescribed manner the
  statement of the tenant whether he is or is not willing to
  purchase the land held by him as a tenant.
  (3) Where any tenant fails to appear or makes a statement
  that he is not willing to purchase the land, the Tribunal shall
  by an order in writing declare that such tenant is not willing
  to purchase the land and that the purchase is ineffective:
  Provided that if such order is passed in default of the
  appearance of any party, the Tribunal shall communicate
  such order to the parties and any party on whose default
  the order was passed may within 60 days from the date on
  which the order was communicated to him apply for the
  review of the same.
  xxx xxx xxx
  (5) In the case of a tenant who is deemed to have
  purchased the land on the postponed date the Tribunal
  shall, as soon as may be after such date determine the
  price of the land .”

• Section 32-M of the Maharashtra Tenancy and Agricultural Lands Act, 1948, states that a purchase by a tenant is ineffective on their failure to pay the purchase price, after which the land is at the disposal of the Tribunal.
• Section 32-O of the Maharashtra Tenancy and Agricultural Lands Act, 1948, states that in respect of any tenancy created after Tillers’ Day, such tenant cultivating personally shall be entitled, within one year from the commencement of such tenancy, to purchase from the landlord the land held by him to the extent of the ceiling area permissible.
• Section 32-P of the Maharashtra Tenancy and Agricultural Lands Act, 1948, empowers the Tribunal to resume and dispose of land not purchased by the tenant.

  “32P.Power of Tribunal to resume and dispose of land
  not purchased by tenant. –
  (1) Where the purchase of any land by tenant under
  Section 32 becomes ineffective under Sections 32-G or 32-
  M or where a tenant fails to exercise the right to purchase
  the land held by him within the specified period under
  Sections 32F, 32O, 33C or 43-1D the Tribunal may suo
  motu or on an application made on this behalf land in case
  other than those in which the purchase has become
  ineffective by reason of Section 32-G or 32-M, after holding
  a formal inquiry direct that the land shall be disposed of in
  the manner provided in sub-section (2).
  (2) Such direction shall provide –
  (a) that the former tenant be summarily evicted;
  (b) that the land shall, subject to the provisions of Section
  15, be surrendered to the former landlord;
  (c) that if the entire land or any portion thereof cannot be
  surrendered in accordance with the provisions of Section
  15, the entire land or such portion thereof, as the case
  may be, notwithstanding that it is a fragment, shall be
  disposed of by sale to any person in the following order of
  priority (hereinafter called “the priority list”):-
  (i) a co-operative farming society the members of
  which are agricultural labourers, landless persons
  or small holders or a combination of such
  persons;
  (ii) agricultural labourers;
  (iii) landless persons;
  (iv) small holders;
  (v) a co-operative farming society of agriculturists
  (other than small holders) who hold either as
  owner or tenant or partly as owner and partly as
  tenant, landless in area than an economic holding
  and who is an artisans;
  (vi) an agriculturist (other than a small holder) who
  holds either as owner or tenant as partly as owner
  and partly as tenant landless in area than an
  economic holding and who are artisan;
  (vii) any other co-operative farming society;
  (viii) any agriculturist who holds either as owner or
  tenant or partly as owner and partly as tenant land
  larger in area than an economic holding but less
  in area than the ceiling area;
  (ix) any person, not being an agriculturist, who
  intends to take to the profession of agriculture:
  Provided that the State Government may, by notification in
  the Official Gazette give in relation to such local areas as it
  may specify, such priority in the above order as it thinks fit
  to any class or person who, by reason of the acquisition of
  their land for any development project approved for the
  purpose by the State Government have been displaced,
  and require to be re-settled.”

The core of the dispute lies in the interpretation of Section 32-F, particularly concerning the one-year period for tenants to exercise their right to purchase land when the landlord was a minor, widow, or person with a disability. The 1969 amendment to Section 32-F(1)(a) added a provision that a minor landlord must intimate the tenant of attaining majority, but it did not include a similar provision for widows or persons with disabilities.

Arguments

Appellants’ (Tenants’) Arguments:

• The appellants argued that the 1948 Act is a social welfare legislation aimed at agrarian reform, protected by Article 31A of the Constitution of India. The 1956 amendment was designed to vest ownership in cultivating tenants, divesting absentee landlords.
• The right of a cultivating tenant to become an owner is only postponed in cases of widows, minors, and persons with disabilities. Section 32-F must be interpreted narrowly to protect the tenant’s right to purchase.
• The 1969 amendment, while addressing minors, did not explicitly include widows or persons with disabilities. However, the legislative intent was to enable tenants to exercise their right of purchase effectively.
• It is crucial that tenants are aware of the cessation of the landlord’s disability to meaningfully exercise their right of purchase. All Division Bench judgments of the Supreme Court that held such knowledge immaterial are incorrect.
• A literal interpretation of Section 32-F would lead to absurd results. For instance, if a tenant is unaware of a widow’s death, the land could revert to an absentee landlord under Section 32-P, defeating the purpose of the 1956 amendment.
• The one-year period for the tenant to exercise the right of purchase should be counted from the date the tenant gains knowledge of the cessation of the landlord’s disability, not merely from the date of cessation itself.
• If Section 32-F is interpreted literally, it would violate Article 14 of the Constitution by discriminating between tenants similarly situated (i.e., those whose rights are postponed due to a landlord’s disability). While minor landlords must inform tenants of their majority, no such obligation exists for widows’ successors, depriving tenants of their rights without fault.

Respondents’ (Landlords’) Arguments:

• The respondents argued that tenants are required to pay rent annually by May 31st, which should make them aware of a widow’s death.
• In Indian village society, news of a widow’s death would spread by word of mouth.
• The Division Bench judgments were correct. Section 32-F contains a non-obstante clause, which must be given full effect.
• The legislature is free to recognize degreesof hardship and does not have to treat all categories of persons equally.
• The legislature has not provided for notice in the case of a widow’s death, and the courts cannot legislate.
• The tenants should have made inquiries about the landlady’s death and not remained idle.
• The tenants did not apply for fixing the price within one year of the landlady’s death, so their right to purchase is lost.

Supreme Court’s Judgment

The Supreme Court, after considering the arguments, reversed the decisions of the High Court and the lower authorities. The Court held that the tenant’s right to purchase land under Section 32 of the Act is not lost merely because the tenant is unaware of the cessation of the landlord’s disability. The key points of the judgment are as follows:

• Social Welfare Legislation: The Court emphasized that the 1948 Act is a social welfare legislation aimed at agrarian reform, designed to vest ownership in cultivating tenants. This purpose must be upheld in interpreting the Act.
• Interpretation of Section 32-F: The Court held that Section 32-F must be interpreted in a manner that does not defeat the purpose of the Act. The one-year period for the tenant to exercise the right of purchase must be counted from the date the tenant gains knowledge of the cessation of the landlord’s disability.
• Legislative Intent: The 1969 amendment to Section 32-F, which mandates intimation by a minor landlord upon attaining majority, reflects the legislative intent that the tenant should be aware of the cessation of the landlord’s disability to exercise their right of purchase. This intent should be extended to other categories of disabled landlords, such as widows and persons with disabilities.
• Absurdity of Literal Interpretation: The Court noted that a literal interpretation of Section 32-F would lead to absurd results, such as the land reverting to an absentee landlord under Section 32-P if the tenant is unaware of the widow’s death. This would defeat the purpose of the 1956 amendment.
• Violation of Article 14: The Court held that a literal interpretation of Section 32-F would violate Article 14 of the Constitution by discriminating between similarly situated tenants. While minor landlords must inform tenants of their majority, no such obligation exists for widows’ successors, depriving tenants of their rights without fault.
• Overruling Previous Judgments: The Court overruled the previous Division Bench judgments of the Supreme Court, which had held that the tenant’s right to purchase is lost if the tenant does not exercise the right within one year of the cessation of the landlord’s disability, regardless of the tenant’s knowledge.
• Duty of Landlord: The Court held that the landlord or their successor-in-interest has a duty to inform the tenant of the cessation of the landlord’s disability. The tenant’s right to purchase is not lost if they are unaware of the cessation of the landlord’s disability.

The Supreme Court, therefore, held that the tenants in this case were entitled to exercise their right to purchase the land, and the one-year period should be counted from the date they gained knowledge of the landlady’s death. The matter was remanded to the Additional Tahsildar to determine the purchase price under Section 32-G.

Implications

The Supreme Court’s judgment in Vasant Ganpat Padave vs Anant Mahadev Sawant has significant implications for tenants, landlords, and legal professionals dealing with land tenancy issues under the Maharashtra Tenancy and Agricultural Lands Act, 1948.

• Protection of Tenant Rights: The judgment protects the rights of tenants, particularly those whose landlords are minors, widows, or persons with disabilities. It ensures that tenants are not deprived of their right to purchase land due to circumstances beyond their control, such as lack of knowledge about the cessation of the landlord’s disability.
• Duty of Landlords: Landlords and their successors-in-interest now have a duty to inform tenants about the cessation of their disability. This obligation ensures that tenants are aware of their right to purchase the land and can exercise it within the prescribed time.
• Legal Certainty: The judgment provides clarity on the interpretation of Section 32-F, resolving the conflict in previous judgments. It establishes that the one-year period for tenants to exercise their right of purchase begins from the date they gain knowledge of the cessation of the landlord’s disability.
• Agrarian Reform: The judgment reinforces the purpose of the 1948 Act as a social welfare legislation aimed at agrarian reform. It ensures that the benefits of the Act reach the actual cultivators of the land, promoting equitable land ownership.
• Legal Practice: Legal professionals must now advise clients on the importance of informing tenants about the cessation of disabilities and the consequences of failing to do so. They must also be aware of the overruled judgments and the new interpretation of Section 32-F.
• Future Cases: The judgment will serve as a precedent for future cases involving similar issues under the Maharashtra Tenancy Act. It will guide the lower courts and tribunals in interpreting the provisions of the Act in a manner that protects the rights of tenants.

Flowchart: Tenant Purchase Rights Under Maharashtra Tenancy Act