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Issues:
1. Applicability of the M.P. Samaj Ke Kamjor Wargon Ke Krishi Bhumidharakon Ka Udhar Dene Walon Ke Bhumi Hadapane Sambandhi Kuchakron Se Paritran Tatha Mukti Adhiniyam (the Act). 2. Retrospective application of the Act to sale transactions. 3. Validity of the sale deeds executed in 1974. 4. Compliance with the provisions of the Act regarding prohibited transactions of loan. 5. Consideration of prevailing market value and restoration of possession of land. Analysis: The Supreme Court addressed the issue of the applicability of the M.P. Samaj Ke Kamjor Wargon Ke Krishi Bhumidharakon Ka Udhar Dene Walon Ke Bhumi Hadapane Sambandhi Kuchakron Se Paritran Tatha Mukti Adhiniyam (the Act) in a case involving a disputed land transaction. The Court examined the provisions of the Act and concluded that the land in question fell within the specified extent of land as defined in Section 2(c) of the Act, making it applicable to the case. The Court rejected the argument that the Act only applied to sale transactions from a specific date, emphasizing that the nature of the transaction, not just the date of sale, determined the Act's applicability. Regarding the validity of the sale deeds executed in 1974, the Court dismissed the argument that an agreement of sale in 1969 rendered the Act inapplicable. The Court clarified that an agreement of sale did not transfer title or interest in the land, which only occurred upon execution and registration of the sale deed. As the sale deeds were executed within the prohibited period, they were subject to the Act's provisions. The Court also examined whether the authorities had properly considered the conditions laid out in the Act regarding prohibited transactions of loan. It was noted that the authorities had found the original transaction to be a prohibited transaction of loan, leading to the sale being declared void. While certain considerations were not explicitly recorded, the Court held that the authorities had substantially complied with the Act's provisions, and the absence of specific findings did not result in a failure of justice. Additionally, the Court addressed the issue of determining the prevailing market value and restoring possession of the land. It was argued that the authorities had not assessed the actual consideration passed and the land's price at the time of sale, as required by the Act. However, the Court found that the authorities' findings fell under a specific provision of the Act, obviating the need for further inquiry. Despite the appellant's offer to pay the market value, the Court upheld the order setting aside the sale and restoring possession to the original landholder. In conclusion, the Supreme Court dismissed the appeal, upholding the lower courts' decisions in favor of the original landowner. The Court emphasized the Act's provisions regarding prohibited transactions of loan and the importance of restoring possession of agricultural land to debtors in such cases.
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