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1953 (2) TMI 47 - SC - Indian Laws

Issues Involved:
1. Constitutionality of the Sathi Lands (Restoration) Act, 1950.
2. Violation of fundamental rights under Articles 14, 19(1)(f), and 31 of the Constitution.
3. Legislative competence and judicial power usurpation.
4. Discriminatory legislation and equal protection clause.

Issue-wise Detailed Analysis:

1. Constitutionality of the Sathi Lands (Restoration) Act, 1950:
The appellants challenged the validity of the Sathi Lands (Restoration) Act, 1950, arguing that it was unconstitutional. The Act declared the settlement of Sathi lands with the appellants as "null and void" and directed their eviction. The appellants contended that this legislation was discriminatory and violated their fundamental rights.

2. Violation of Fundamental Rights under Articles 14, 19(1)(f), and 31 of the Constitution:
The appellants argued that the Act violated their fundamental rights guaranteed under Articles 14 (right to equality), 19(1)(f) (right to property), and 31 (right to compensation for property acquired). The Court focused on Article 14, which ensures equal protection of the laws. The appellants claimed that they were discriminated against as the Act singled them out while other lessees under similar circumstances were not subjected to the same treatment.

3. Legislative Competence and Judicial Power Usurpation:
The appellants argued that the Bihar Legislature usurped judicial power by enacting a law that effectively decided a dispute between private parties without judicial adjudication. The Court emphasized that in a free and civilized society, disputes over legal rights should be determined by duly constituted courts, observing procedural safeguards such as the right to be heard and to produce evidence. The Act bypassed these safeguards, denying the appellants the protection guaranteed by law.

4. Discriminatory Legislation and Equal Protection Clause:
The Court found that the Act was discriminatory as it singled out the appellants and declared their lease null and void without any judicial determination. The legislation lacked a rational basis for classification and failed to justify the discrimination. The Court noted that numerous other lessees received similar settlements but were not subjected to the same expropriatory legislation. The Act deprived the appellants of their right to have their dispute adjudicated by a judicial tribunal, which constitutes a severe form of discrimination.

Judgment Summary:
The Supreme Court held that the Sathi Lands (Restoration) Act, 1950, was unconstitutional as it violated the appellants' fundamental rights under Article 14 of the Constitution. The Act was discriminatory, lacked a rational basis for classification, and usurped judicial power by deciding a private dispute without judicial adjudication. The Court allowed the appeal, set aside the judgment of the High Court, and issued a writ of mandamus directing the respondents not to take any steps under the impugned Act or interfere with the appellants' possession of the lands in question.

Separate Judgments:
- M. Patanjali Sastri, C.J., concurred with the judgment delivered by Mukherjea, J., and emphasized the importance of constitutional issues involved.
- Vivian Bose, J., Ghulam Hasan, J., and N.H. Bhagwati, J., agreed with the judgment delivered by Mukherjea, J., and had nothing further to add.

Conclusion:
The Supreme Court's decision underscores the importance of equal protection under the law and the necessity for legislative actions to be non-discriminatory and within constitutional bounds. The judgment reaffirms the judiciary's role in adjudicating disputes and protecting individual rights against arbitrary legislative actions.

 

 

 

 

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