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Issues Involved:
1. Interpretation of Articles 31A and 31B of the Constitution of India. 2. Validity of Section 6 of the Gujarat Agricultural Land Ceiling Act, 1961. 3. Legislative competence and the concept of "person" under the Act. 4. Impact of Article 31B on legislative provisions. 5. Interaction between Article 31A and Article 31B. Detailed Analysis: 1. Interpretation of Articles 31A and 31B of the Constitution of India: The core issue revolves around the interpretation of Articles 31A and 31B in relation to the Gujarat Agricultural Land Ceiling Act, 1961. The Act aims to impose ceiling limits on agricultural land holdings and facilitate the redistribution of surplus land. The appellants argued that the Act's provisions, particularly Section 6, contravene the second proviso to Article 31A(1), which protects land under personal cultivation from acquisition without compensation at market value. 2. Validity of Section 6 of the Gujarat Agricultural Land Ceiling Act, 1961: Section 6 of the Act stipulates that no person shall hold land in excess of the ceiling area. It includes provisions for grouping land held by individuals and their families to determine ceiling limits. The appellants contended that this grouping mechanism is a "colourable device" to bypass the limitations imposed by Article 31A(1). The Court, however, found that Section 6 does not merge or destroy separate legal personalities but merely groups holdings for ceiling determination. The Act's objective is to limit land holdings and redistribute surplus land, and compensation is provided for acquisitions exceeding the ceiling area. 3. Legislative Competence and the Concept of "Person" under the Act: The term "person" includes both individuals and families as defined by the Act. The appellants argued that the Act's definition of "person" is unnatural and legally untenable. The Court clarified that the term "person" is inclusive and does not exclude individuals. The Act's provisions requiring the grouping of family holdings do not affect the legal status or competence of individuals but reduce their holdings proportionately. The Court found no fixed concept of "person" that the Act violates and upheld the legislative competence to prescribe varying ceiling limits for different individuals or classes. 4. Impact of Article 31B on Legislative Provisions: Article 31B protects laws included in the Ninth Schedule from being deemed void due to inconsistencies with Part III of the Constitution. The Court held that Article 31B provides a complete answer to any attack on the Act based on alleged violations of Part III rights. The appellants conceded that, in light of precedents, it is not possible to challenge Section 6 on these grounds. The Court emphasized that Article 31B shields the Act from invalidity due to legislative incompetence or alleged breaches of constitutional rights. 5. Interaction between Article 31A and Article 31B: The Court noted that Articles 31A(1) and 31B operate in different fields but can provide dual protection to legislation. Article 31A(1) addresses potential invalidities due to inconsistencies with Articles 14, 19, or 31, while Article 31B offers broader protection from conflicts with any Part III provisions. The Court rejected the argument that Article 31B does not shield the impugned provisions from the limits imposed by the second proviso to Article 31A(1). The Court concluded that even if the second proviso were infringed, Article 31B would repel such an attack, as both articles aim to protect against constitutional breaches. Conclusion: The Supreme Court dismissed the appeals, affirming the validity of Section 6 of the Gujarat Agricultural Land Ceiling Act, 1961. The Court upheld the legislative competence to define "person" inclusively and to impose varying ceiling limits. It emphasized the protective scope of Article 31B and the dual applicability of Articles 31A(1) and 31B in safeguarding the Act from constitutional challenges. The parties were directed to bear their own costs.
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