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Issues Involved:
1. Legislative competence of the State Legislature to enact the Punjab Security of Land Tenure Act. 2. Alleged contravention of fundamental rights under Articles 14, 19(1)(f), and 31 of the Constitution. 3. Whether the provisions of the Act amount to unreasonable restrictions on the petitioners' rights to hold and dispose of property. Issue-wise Detailed Analysis: 1. Legislative Competence: The primary argument against the legislative competence was based on Entry 18 in List II of the Seventh Schedule to the Constitution, which pertains to "Land, that is to say, rights in or over land, land tenures including the relation of landlord and tenant, and the collection of rents; transfer and alienation of agricultural land; land improvement and agricultural loans; colonization." It was contended that this entry does not authorize the State Legislature to limit the extent of land a proprietor or landowner can hold. The court, however, found that the entry, read with Article 246(3) of the Constitution, vests exclusive power in the State to make laws concerning "rights in or over land, land tenures including the relation of landlord and tenant." The Act's provisions, which modify landlords' rights and expand tenants' rights, fall within this ambit. The court referenced past judgments, including those of the Federal Court and the Privy Council, which supported a broad interpretation of such legislative entries, emphasizing that they should not be read in a narrow or restricted sense. 2. Alleged Contravention of Fundamental Rights: The petitioners argued that the Act contravened their fundamental rights under Articles 14, 19(1)(f), and 31. However, the court noted that if the Act falls within the purview of Article 31A, it is immune from such attacks. Article 31A protects laws that provide for the acquisition by the State of any estate or of any rights therein, or for the extinguishment or modification of any such rights. The court found that the Act does indeed modify rights in estates, as it limits the landowners' rights and expands tenants' rights, thus falling within the protective ambit of Article 31A. The court further explained that the definition of "estate" and "rights" in Article 31A is broad and includes both quantitative and qualitative rights, covering portions of estates as well. 3. Unreasonable Restrictions on Property Rights: The petitioners contended that certain provisions of the Act imposed unreasonable restrictions on their rights to hold and dispose of property. The court, however, concluded that the Act's provisions, which modify the landowner's rights, such as setting land terms, cultivating surplus areas, and transferring land, are substantial modifications of rights in estates. As these modifications are protected by Article 31A, the arguments based on unreasonable restrictions under Articles 14, 19, and 31 are not sustainable. The court dismissed the petitions, affirming the Act's constitutionality and legislative competence, and ruled that the restrictions imposed by the Act were reasonable and in line with agrarian reforms aimed at creating a class of small landowners. Conclusion: The Supreme Court dismissed the petitions, upholding the constitutionality of the Punjab Security of Land Tenure Act. The court affirmed the State Legislature's competence to enact the law under Entry 18 of List II and found that the Act's provisions were protected by Article 31A, thereby immunizing it from challenges based on Articles 14, 19, and 31. The Act's restrictions were deemed reasonable, serving the objective of agrarian reform and the creation of small landowners.
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