TABLE OF CONTENTS:

Sr.no. Title Page no.

01 Introduction 03

02 Nature of cases 04
03 Why cases have been selected 05

04 Time period covered 06

05 Case no. 01 Kajimuddy and Ors. 07-10
Vs.
The Secretary of State for India in Council
06 Case no. 02 Raja Raghubir Sahi 11-12
Vs.
Maharajah Sri Protap Udoy Nath Sahi Deo
07 Case no. 03 Banamali Satnathi 13-14
Vs.
Choudhuri Artaran Mahapatra
08 Conclusion 15

09 Sustainable Development 16

10 Executive summary 17

11 Bibliography 18

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INTRODUCTION:
It might be one of the least researched aspects of law but is certainly not the least important.
When we hear this word Tenancy, what comes in our mind? , what meaning does tenacy means?
And what is its importance? For the simple understanding Tenancy means, Where two or more
persons take an estate or interest in land by means of an application, transfer, mortgage, charge
or lease that dealing must state whether the persons are to hold as joint tenants or tenants in
common. If they hold as tenants in common the share of each person must also be stated.

A tenant in common holds an undivided share in the property and has unity of possession. This
means that each co-tenant has an equal right to possession of the whole of the property, but not a
right to exclusive possession of any part. A tenant in common may deal with their respective
share as they wish and this will not affect the tenancy of the other co-tenants.

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NATURE OF CASES:
I have choosen three cases which are of civil in nature, under the subject of Tenancy. Here,
Bengal Tenancy Act (VIII of 1885), Chota Nagpur Tenancy Act (VI of 1908) and Orissa Tenancy
Act,1913 have been referred to.

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WHY CASES HAVE BEEN SELECTED:
I have choosen these three cases in keeping the fact in my mind that this is one of the aspects of
law which have been least studied and researched and if I am going to research on this, it would
not only help me to understand about tenancy but will also be very useful to all the readers who
goes through this research paper.

I originally belongs to the state of Bihar but I had also spent my few years in the state of
Jharkhand and the tenancy is a big issue in the state of Jharkhand, so I felt related while doing
this research paper.

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TIME PERIOD COVERED:
The time period which have been covered in this research paper varies from as early as 1985 to
the extent of 1918, which covers a reign of around three decades. The three cases which have
been incorporated in this research paper are of three different years i.e. 1895, 1911 and 1918
respectively. The important aspect of this time period is that it is after the formation of Indian
National Congress but before the arrival of Mahatma Gandhi in the independence movement. It
was also the period when many administrative changes were going on and laws regarding
tenancy came into force.

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CASE NO 1:
IN THE HIGH COURT OF CALCUTTA
Decided on : 31.07.1895

Appellants: Kajimuddy and Ors.

Vs.
Respondent: The Secretary of State for India in Council

FACTS OF THE CASE:

This is an advance from a request of remand passed by the Subordinate Judge of Tipperah under
Section 562, Code of Civil Procedure. The offended parties are inhabitants of a Government
domain arranged in Pergunnah Singargaon in the Region of Tipperah, and the respondent is the
Secretary of State for India in Committee. By a notice, dated the sixth November 1888 (see Part
I, page 943, of the Calcutta Gazette of the seventh November 1888), the Local Government made
a request under Section 101 (1) of the Bengal Tenancy Act, guiding that an overview be made
and a record of rights be arranged in admiration of all terrains included in the domain being
referred to, and pointing out in that the particulars to be recorded as needed by Section 102 of the
Act; and by an alternate notice of the same date, Babu Kali Sankar Sen, Deputy Gatherer, was
selected Settlement Officer of that domain. After the request had been made and the record of
rights arranged, the Settlement Officer, of his own particular movement, settled what seemed to
him to be a reasonable and fair lease in admiration of the terrains held by the offended parties
and different occupants, under the procurements of Clauses (2) and (3), Section 104, of the
Tenancy Act. Having finished the record, he brought about a draft thereof to be by regional
standards distributed under Segment 105 (1), and immediately the offended parties favored a
protest under that segment to specific sections in that upgrading their rents, on the ground that
their rents were not at risk to be improved. This complaint was considered and prohibited by an
alternate properly enabled Settlement Officer, Rajany Kumar Dutt, the successor in office of
Babu Kali Sankar Sen. Having discarded the protests, the Settlement Officer at long last
surrounded and distributed the record (khatian) under Section 105 (2). The offended parties did
not advance against the Settlement Officer's requests passed under Sections 104 and 105 of the
Tenancy Act, however they founded the present suit to have the incidents of the Settlement
Officer concerning the settlement of their rents put aside, mostly in light of the fact that his
transactions are illicit and invalid; and that his choice has not the energy of an announcement,
and is not tying on them. The main ground of resistance is that the suit is banished by the
procurements of the Tenancy Act; that the choice of the Settlement Officer has the energy of an

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announcement; and that the inquiry chose by him is res judicata, and can't be revived and
attempted by the Civil Court. The educated Munsif offered impact to this resistance and released
the suit. He was of assessment that the choice of the Settlement Officer under Sections 104 and
105 worked as res judicata, and that the main cure open to the offended parties was to have spoke
to the Special Judge. On offer, the educated Subordinate Judge put aside the announcement of
the Munsif and remanded the suit for trial on the benefits. He held that the Settlement Officer
had no ward to settle the rents of the offended parties under Section 104, and that, regardless of
the possibility that he had, his choice in such processes has not the power of an announcement
under Section 107, and that the guideline of res judicata does not have any significant bearing.

In second appeal by the defendant, it is contended before the court that the learned Subordinate
Judge has taken an erroneous view of the law, and thathe ought to have held that the suit is
barred by the provisions of the Tenancy Act.

The main inquiry to be dead set is, whether the Settlement Officer had purview under the
Tenancy Act to settle leases in appreciation of the area held by the offended parties. Presently it
is conceded that the Settlement Officer was most certainly not contributed under Section 112 of
the Act with forces to settle all the rents in this bequest, and further that not the offended parties
or the litigant connected for a settlement of rent under Section 104 (2), so that with a specific end
goal to give the Settlement Officer purview to settle the rents suo motu it must have seemed to
him that the offended parties were holding land in overabundance of, or less than, that for which
they were paying rent [see section 1, Clause (2), of segment The Subordinate Judge watched that
this does not show up, either on the substance of the processes (Exhibit An) of the Settlement
Officer under Section 104, or from the khatian, or record, as at last confined by him under
Section 105, and doubtlessly is so. The transactions (A) just show that the Settlement Officer
improved the rents, on the ground that there had been an ascent in the normal cost, of rice, and
further there is no section in the khatian of the zone of the offended party's holding before the
review. In any case however that may be, it is clear from the plaint itself that it is the offended
parties' case that the Settlement Officer found by estimation that the zone of their holding was in
overabundance of that for which they had been paying rent. In section 1 of the plaint the
offended parties say the zone of their holding is 9 kanis, what's more in section 2, that the
Settlement Officer "distributed a draft khatian expressing, in addition to everything else, that the
said amount of area was 103 bighas 1 kattah 10 chattacks;" and, once more, in section 3, the
offended parties take special case to the length of the shaft of estimation utilized by the
Settlement Officer in measuring their territories, whereby the zone thereof was expanded. In the
substance of these confirmations, we don't surmise that it could be fought that the Settlement
Officer had no ward to settle rents, simply in light of the fact that it does not show up on the
substance of his processes under Section 104, that he settled the rents on the ground that the area
held by the offended parties was in abundance of that for which they were paying rent. What's
more as respects the khatian, we watch that there is no segment gave in it to demonstrating the
zone of the land preceding the review (see type of khatian given in Rule 9 of the standard

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published by the Local Government on the 21st December 1885 under Subsection 5, Section 190, of the
Tenancy Act); so that such area could not been entered therein. We are, therefore, unable to agree with the
Subordinate Judge that the Settlement Officer had no jurisdiction to settle rents under Section 104 of the Act.
The next question is, what is the legal effect of the Settlement Officer's proceedings under Sections 104 and
105 of the Tenancy Act.

JUDGEMENT:

The determination of this inquiry is not free from trouble, however after providing for it our best
attention, we are of supposition that the Subordinate Judge is right in holding that the suit is not
banished by the guideline of res judicata, then again by the procurements of the Tenancy Act. We
have sent for and inspected the unique records of the incidents of the Settlement Officer under
Sections 104 and 105 with the end goal of learning what was the accurate character of those
transactions, and it seems to us that they were of an official, instead of a legal, character. Under
Rule 16 of the tenets declared by the Local Government, the Settlement Officer issued a notice
(see type of notice at the end of Schedule I of the principles), which, in addition to different
matters, contained the accompanying: "1 should, likewise, at the said time and place, or at such
other time to which the transactions may be suspended, move ahead, on the application formerly
made of either proprietor or inhabitant, to settle reasonable and impartial leases under Section
104, Sub-areas '2 and 3, of the said Act. Moreover perceive is given that if it then give the idea
that any occupant is holding land in overabundance of, or short of what, that for which he is
paying rent, and should not the landowner or inhabitant apply to have a reasonable rent settled, I
should, as per the said segment of the Tenancy Act, continue of my own particular movement to
settle a reasonable and fair lease for such inhabitants' holding." Also, as we have officially said,
none, of these the proprietor (the Government in the present case), nor inhabitant sought a settle-
mmit of rent. A few occupants, nonetheless, displayed petitions to the Settlement Officer, in
which they expressed that their rents were not subject to be upgraded, and the Settlement Officer,
in the wake of bringing down the statements of some of these candidates and some different
persons, chose that the rates of every last one of occupants of the bequest were subject to be
upgraded, on the ground expressed in his progressing, dated the fifth Walk 1890 (Exhibit A).
There was along these lines, we think, no suit before the Settlement Officer in the best possible
feeling of the term. The proprietor was no gathering to the progressing. There was no offended
party and no litigant showed against one another. There was, indeed, no challenge, and no issue
was raised for determination between any fighting gatherings. In these circumstances, we think it
is truly difficult to hold that Section 13 of the Civil Procedure Code has any way of use to the
present case, or that the choice of the Settlement Officer settling the inhabitant's rents under
Section 104 works under Section 107 as a last declaration, estopping the present offended parties
from having the same matters attempted by the customary Civil Court. The same perceptions

9
apply to the request of the Settlement Officer passed under segment 105 on the protest of the
offended parties. That request was not parsed in a suit or in any challenge in the middle of
landowner and inhabitant. All that shows up is that some nearby enquiry was held and the protest
was prohibited.

It was contended before us that the passages in the khatian, to which complaint was taken by the
offended parties, are questioned passages, and that, hence, the choice by the Settlement Officer
in appreciation of those passages is last.-See the instance of Gokhul Sahu v. Jodu Nundun Roy
I.l.r. Cal. 721. We can't acknowledge this perspective. The words "complaint" and "question" are
not synonymous terms, and we don't imagine that they are utilized as a part of the same sense in
Sections 105 and 106 of the Tenancy Act. As we would like to think these passages are,
legitimately talking, undisputed passages, and, under Section 109, are to be ventured to be right,
until the opposite is demonstrated. A suit in the Civil Court will appropriately deceive make the
error of these passages, and we watch that Section 111 of the Act ponders the foundation of such
a suit after the last distribution of the record. All in all we think the choice of the Subordinate
Judge is correct, and we reject this offer with expenses. The case will backpedal to the first Court
for trial of the remaining issues.

ANALYSIS OF LEGAL ASPECTS:

This case in the High Court of Calcutta is civil in nature and falls under the subject of Tenancy
of Bengal Tenancy Act (VIII of 1885), Section 104, Clauses (2), (3); Section 105, 107 Civil
Procedure Code (Act XIV of 1882), Section 13 objection dispute.

The court dismisses the appeal with costs and ordered that the case will go back to the first court
for trial of the remaining issues.

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Case 2:
IN THE HIGH COURT OF CALCUTTA
Decided On: 29.11.1911
Appellants: Raja Raghubir Sahi
Vs.
Respondent: Maharajah Sri Protap Udoy Nath Sahi Deo

FACTS OF THE CASE:

1.This case comes before the court on appeal and also on a Rule. The appeal was
from a decree of the Judicial Commissioner of Chota Nagpur sitting on appeal
from an order under Section 87 of the Chota Nagpur Tenancy Act.

2. A preliminary objection is taken by the respondent that no second appeal

lies in this case, and this contention, we think, must succeed. Sub-section
(2) of Section 87 of the Act enacts that an appeal shall lie in the prescribed
manner and to the prescribed officer from decisions passed under Subsection
(1). By an order of the Local Government, which has power to act in
this matter, the prescribed officer is the Judicial Commissioner, and it is
argued that an appeal lying to him from a decision of a Revenue officer there
can be no second appeal. It is admitted that the provisions of Section 100,
Civil Procedure Code, must be excluded either expressly or by implication.
There is no express exclusion in this Act, but we think, on looking at the
frame-work of this Act, that it is intended that no second appeal should lie to
this Court. An appeal is provided for, as we have said, in Sub-section (2) of
Section 87, and if there is to be a further appeal we must then look to the
provisions of Section 224 of the Act, which lays down that "A second appeal
shall lie to the High Court, under Chapter XLII of the Code of Civil Procedure,
from an appellate decree passed by the Judicial Commissioner under this
Chapter, or from any order passed by him on appeal under Section 215, Sub section (3)".

JUDGEMENT:
Stephen, J.

The court is of opinion that Section 87 has been deliberately

excluded from its scope, we are led further to this conclusion by a
consideration of the provisions of the Bengal Tenancy Act from which
this Act has been very closely adopted. Reading Section 87 with Section 108
of the Bengal Tenancy Act, it seems to us that it is by implication provided
that there shall be no second appeal in cases arising under that section. He, therefore, hold that there is no
second appeal in this case and the appeal have been dismissed with costs by him.

Coxe, J.

He agree. It appears to him that Clause (2) Section 87, read with Section
264, Sub-section (1), Clause (8) is tantamount to an express provision of law
within the meaning of Section 100 of the Code of Civil Procedure, that these
appeals should be heard by the prescribed officers and should not be heard

11
by officers other than those. he only desire to state that in the case of
Mohunt Padmalav Ramanuja Das v. Lukshmi Rani 12 C.W.N.S. to which we
have been referred, there is nothing that in any way limits the scope of
Section 106 of the Bengal Tenancy Act in so far as it relates to suits
between landlord and tenant. The appeal is dismissed with costs.

He had then to consider this Rule. The Rule was on the opposite party to
show cause why the decision complained of should not be set aside. The
decicion arrived at was that the petitioner was a tenant for life and not
possessed of a tenancy of a hereditary nature. It is argued on his behalf
that the judicial Commissioner acted whithout jurisdiction in deciding this
question. Under section 81, however, It is the duty of the Settlement officer
under Section 87 to decide the matters contained in Section 81, paragraph
(b).IT, therefore, was clearly his duty to decide the question which he has
decided and we cannot see that there is any room for the contention that he
has acted without jurisdiction .The Rule is discharged without Costs.

ANALYSIS OF LEGAL ASPECTS:

Under this case in the High Court of Calcutta, the Chota Nagpur Tenancy Act (VI of 1908) had
been applied to solve this dispute.

Along with this Section 87 and 224 of Civil Procedure Code (Act V of 1908) also comes into
force . Section 100 Second Appeal order under Section 87 of Chota Nagpur Tenancy Act also
governs this case.

The disposition of this case was made by the High Court of Calcutta by dismissing the appeal
with costs. The Rule is discharged without costs in this case by the court.

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CASE 03.
IN THE HIGH COURT OF PATNA
Civil Revision No. 23 of 1918
Decided On: 19.12.1918
Appellants: Banamali Satnathi
Vs.
Respondent: Choudhuri Artaran Mahapatra

FACTS OF THE CASE:

1.The question for decision in this case is whether a Civil Court is a Court having jurisdiction to determine a
suit for the possession of land within the meaning of section 210 of the Orissa Tenancy Act, 1913. That section
provides that such a Court, on the application of either the landlord or the tenant, may determine all or any of
the following matters, namely:-- (d) The rent payable by him at the time of the application.
2. An application was made under that section to a Civil Court presided over by a Munsif and th Munsif came
to the conclusion that the rent payable was that contended for by the landlord,which was Rs. 7 odd, and not
that contended for by the tenant, which was Rs. 3 odd. That decision is brought before us by way of revision
and we are asked to say that the Munsif's Court had no jurisdiction to entertain such an application, and we are
referred to section 193 of the Act which provides that.
The following suits and applications shall be cognizable by the Collector,
and shall be instituted and tried or heard under the provisions of the Act,
and shall not be cognizable in any other Court except as provided in
thisAct, namely:--(a) All suite and applications under any portion of
this Act other than Chapter XI.
3. The application in question admittedly did not come under Chapter XI and, therefore, prima facie it would
be under section 193 one of the applications which would be triable by the Collector only and not by the Civil
Court, but section 193 only provides that these suits and applications shall not be cognizable in any other Court
except as provided in this Act, and the question which we have to determine here is, whether it is provided in
section 210 that a Civil Court shall have jurisdiction to determine ore of the applications mentioned in that
section. The section itself is quite clear and
unambiguous. It is taken and repeated verbatim, I believe, from section 158of the
Bengal Tenancy Act. It refers to the Court having jurisdiction to determine a suit for the
possession of land. That may be either a Civil Court or a Revenue Court as the case may be, but as things are,
there is no reason, so far as I am' aware, why a Civil Court should be deprived of its ordinary jurisdiction to
determine a suit for the possession of land, and if that is so, it is quite clear that a Civil Court is one of the
Courts referred to in section 210.
4. But it is suggested that section 193, which makes all suits and applications under any portion of this Act
triable by the Collector only, imports this that all suits of any nature which are referred to or in which any
provisions of thisAct may be applied are suits under this Act. I confess that I have some difficulty in following
that argument. It does not seem to me that an ordinary suit which is triable by the Civil Courts is a suit under
this Act at all. There are certain suits and certain applications which undoubtedly are made under this Act, that
is to say, the Orissa Tenancy Act, and there are certain classes of cases which are said by the terms of the Act
itself to be triable only in a certain way either by a Civil Court or a Revenue Court or in some other way as the
case may be.

13
JUDGEMENT:

It seems to the court, looking at this section, that there is no ground for holding that an ordinary suit for the
possession of land is a suit or application under any portion of this Act at all. It may be, and the court believes
that it is a fact, that certain suits for ejectment against tenants, which of course involve a claim for possession
of land, are triable only in a certain way, but the words of section 210 are general in their application and I
think that the words there used "the Court having jurisdiction to determine a suit for the possession of land"
must mean any Court which has that jurisdiction, in this case the Civil Court, unless it can be shown that that
jurisdiction is taken away by some provision in the Act itself. In these circumstances the court think this
application must be
dismissed with costs.

ANALYSIS OF LEGAL ASPECTS:

This case in the High Court of Patna had been dealt under Orissa Tenancy Act, 1913 Section
210.
Orissa Tenancy Act (II B.O. of 1913), ss. 193, 210 - "Court having jurisdiction to determine suit
for the possession of land," whether includes Civil Court--Jurisdiction of Civil and Revenue
Courts--Civil Court, whether can determine rent.
The provisions of section 210 of the Orissa Tenancy Act are general in their application and
the words "the Court having jurisdiction to determine a suit for the possession of land" in
the section mean any Court which has that jurisdiction, unless it can be shown that that
jurisdiction is taken away by some provision in the Act itself.

Therefore, a Civil Court has jurisdiction to determine the rent payable by a tenant under
section 210(1)(d) of the Orissa Tenancy Act.

Civil revision from an order of the Munsif, Kendrapara, dated the 15th May 1918.

The court dismissed the application with costs.

14
CONCLUSION:

The land reforms refer to the reforming of defective structure of the land holdings and are a
planned and institutional organization of the relation between man and land. The agriculture
system that existed at the time of independence consisted of several defects including that of
tenancy i.e., the insecurity of tenure and high rents charged by the landlord. The reforms aimed
to eliminate all forms of exploitation and social injustice within the agrarian system, to provide
security for the tiller of the soil and to remove such impediments to increase in agricultural
production as arise from the agrarian structure inherited from the past. One of the major aspects
of the land reforms in India has been the tenancy reform.

Under the Zamindari and ryotwari systems, tenancy cultivation had been quite common in India.
Tenancy cultivation may be done by small proprietors who find that they have an insufficient
quantity of land or it may be carried on by landless labourers. Sometimes, the tenants holding
land from an intermediary may sub-let it for cultivation.

Land reforms helped new classes/castes to gain political power directly/indirectly. The
participation of the backward classes deepened Indian democracy. Indian democracy became
more inclusive. Political system became more competitive and complex. These laws gave the
lower castes the security of tenure over farmland + land ceiling + zamindari abolition+
Panchayati Raj reforms. Result: Influence/domination of upper caste declined in village power
structure. Thus, Constitutions promise of giving justice social, political and economic,
became a reality. In the Ryotwari areas of Bombay state (MH + Guj), ~50% of the tenants
became landowners- including inferior tenants. Even in former zamindari areas such as West
Bengal, nearly half the sharecroppers got occupancy rights under Operation Barga .Now the
tenants and sharecroppers who got occupancy rights => they had the motivation of becoming
progressive farmers, use high yielding variety, invest more capital etc.
So far, we learned three major land reforms measures in post independent India:

1. Zamindari abolition

2. land ceiling

3. tenure reforms

The most important beneficial result of the reform is that it put an end to the system of parasitic
intermediaries. On the other hand it has not put an end to absentee ownership of land nor has it
lead to the disappearance of tenancies. All in all, although the contribution of tenancy reforms
could not be totally neglected but the programmes including these reforms since independence
did not lead into any significant redistribution of land, or the removal of all the obstacles to
increasing agricultural production. The policies adopted in case were ambivalent and there were
large gaps between policy and legislation and implementation.

15
SUSTAINABLE DEVELOPMENT:
The Rent Act of 1859 was considered as a landmark as well as the first step in the evolution of
tenancy legislation and peasant's rights. It is interesting to note that in 1857 a Bill was introduced
which was originally meant for amending the existing law relating to the recovery of rent.
During the progress of the Bill, substantial additions were made because of which it took a new
shape in the form of the Rent Act X of 1859. The Rent Act provided for the first time a
defamation of the right of occupancy over land both for the zamindars and the tenants. However,
the Act could not provide the desired result as far as the occupancy right was concerned. The Act
conferred occupancy rights on tenants who had held land for twelve years. Judicial decisions
after a few years of the passing of this Act clearly brought out that the occupancy rights it
intended to give were not actually available, because the provision of holding land for twelve
years for claiming occupancy right could be easily violated by the landlord by shifting the tenant
from one plot to another. There were many other drawbacks of the Rent Act including the one
that it did not put any restriction on the enhancement of rent by the zamindar. In 1880, the Rent
Law Commission was appointed to prepare a draft Tenancy Bill which formed the basis of the
Bengal Tenancy Act, 1885. As far as possible the Bengal Tenancy Act tried to remove the defects
of the Rent Act of 1859 and to provide a self contained agrarian code to the province. However,
this entire Act was not made applicable to the Orissa Division. The extension of the Act to Orissa
was made piece-meal in 1891. The Rent Act of 1859, that was consistent with the extended
provisions of the Bengal Tenancy Act, continued to be in force in Orissa at least up to 1913. In
course of the Provincial Settlement of 1890-1900 S.L. Maddox, the Settlement Officer, continued
detailed inquiries about different rights in land and carefully reviewed the applicability of various
provisions of the Bengal Tenancy Act to Orissa. 7 It was then found that the extension of the
provision of conferring occupancy right upon tenants for possessing same land for twelve years
had brought remarkable changes in the tenurial relations in Orissa. The said twelve years rule
was continued in the Bengal Tenancy Act, but it went one step further by extending this principle
to the extent that any person who had continuously held land as a raiyat in any village for twelve
years became a "settled raiyat" of the villages.

Various State governments have passed the laws to protect the land owners and
(superior+inferior) tenants. Collectively these are called tenancy reform acts.Such tenancy
reform acts, usually have five elements: two for land owners + three for tenantsbut first, lets
once again check the players in a tenancy system, to get a better grip over this tenure/tenancy
reform acts. Tenacy reform acts by and large protect only superior and inferior tenant.
Sharecroppers/Laborers get nothing. Anyways, lets check the salient features of such Acts in
various states:

16
EXECUTIVE SUMMARY:
In this research paper, I have studied and researched upon or about the tenancy act in its detail
for which i have incorporated three cases related to tenancy act through the period of about three
decades. I have analysed the legal aspects of all the three cases related to Tenancy Act which
deals with Bengal Tenancy Act, 1885; Chota Nagpur Tenancy Act,1908 and Orissa Tenancy
Act,1913 .

I have also tried to show the evolution and sustainable development of Tenancy Act in India
before and after the independence and concluded the research paper by critically analysing the
Tenancy Act and reforms that took place related to that.

In this research paper, diagnostive method of research have been applied with the view of
qualitative study of the Tenancy Act. Both kinds of sources i.e. primary and secondary sources
have been taken into consideration while carrying out this research paper.

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BIBLOGRAPHY:
AIR

Constitution of India

ILR

legalserviceindia.com

Manupatra

SCC

shodhganga.inflibnet.ac.in

Wikipedia

www.lpi.nsw.gov.au

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