In Brief
The Supreme Court upheld a High Court decision invalidating an exemption certificate granted by a Collector to a religious temple trust under the Bombay Tenancy and Agricultural Lands Act, 1948. Tenant occupants on 'Tillers' Day' (1 April 1957) became deemed purchasers of agricultural land under Section 32 of the Act. A religious trust registered after that date cannot claim exemption from deemed purchase provisions, as registration takes prospective effect only. Even though the trust was a valid public trust for religious purposes, the statute requires registration before Tillers' Day for exemption eligibility. The respondent-tenants' vested purchase rights could not be divested by subsequent trust registration. The appeal was dismissed, affirming that statutory land reforms apply to religious trusts.
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