In Brief
The Supreme Court dismissed the appeal by a purchaser who had bought agricultural land from beneficiaries of SC/ST government grants, with transactions executed after the fifteen-year non-alienation period. The appellant argued no permission was needed post-fifteen years. The Court held that Section 4(2) of the Karnataka SC/ST Lands Act 1978 imposes an absolute, perpetual bar on transferring granted land without Government permission—not limited to the five-to-fifteen-year window. The Act's protective purpose for vulnerable communities meant permission was required regardless of timing. The Court dismissed the appeal and upheld the competent authority's nullification of the sale deeds.", <parameter name="cited_cases">[{"raw_citation": "(1984) 3 SCC 301", "case_name": "Manchegowda & Ors. v. State of Karnataka & Ors.", "cited_year": "1984", "paragraph": "9, 10, 11, 17, 32, 33", "treatment": "distinguished", "treatment_by": "this_court", "treatment_quote": "The context of the observations made in Manchegowda v. State of Karnataka, (supra) has to be read. It is noted that the agreements for sale were executed before the commencement of the Act. The sale deed was executed afterwards. In that context it was observed that it could be safely concluded that provisions of Section 4(1) declared any transfer of land made either before or after the commencement of the said Act to be null and void if it contravened the conditions specified therein. Section 4(2) was held to make it abundantly clear that if the sale deed was executed and registered after the commencement of the said Act, and was without prior permission of the State Government, such transfer would be invalid and null and void."}, {"raw_citation": "(2003) 7 SCC 667", "case_name": "Ibrahimpatnam Taluk Vyavasaya Coolie Sangham v. K. Suresh Reddy & Ors.", "cited_year": "2003", "paragraph": "12", "treatment": "referred", "treatment_by": "this_court"}, {"raw_citation": "(2004) 8 SCC 340", "case_name": "Situ Sahu & Ors. v. State of Jharkhand & Ors.", "cited_year": "2004", "paragraph": "12", "treatment": "referred", "treatment_by": "this_court"}, {"raw_citation": "(2018) 12 SCC 527", "case_name": "Chhedi Lal Yadav & Ors. v. Hari Kishore Yadav (Dead) through Legal Representatives & Ors.", "cited_year": "2018", "paragraph": "12", "treatment": "referred", "treatment_by": "this_court"}, {"raw_citation": "Civil Appeal No. 2166/2009", "case_name": "Vivek M. Hinduja v. M. Aswatha & Ors.", "cited_year": "2017", "paragraph": "12", "treatment": "referred", "treatment_by": "this_court"}, {"raw_citation": "(2008) 14 SCC 517", "case_name": "Dharma Naika v. Rama Naika & Anr.", "cited_year": "2008", "paragraph": "20, 33", "treatment": "followed", "treatment_by": "this_court", "treatment_quote": "The context of the observations made in Manchegowda v. State of Karnataka, (supra) has to be read. It is noted that the agreements for sale were executed before the commencement of the Act. The sale deed was executed afterwards. In that context it was observed that it could be safely concluded that provisions of Section 4(1) declared any transfer of land made either before or after the commencement of the said Act to be null and void if it contravened the conditions specified therein."}, {"raw_citation": "(2004) 9 SCC 780", "case_name": "Harishchandra Hegde v. State of Karnataka & Ors.", "cited_year": "2004", "paragraph": "20", "treatment": "referred", "treatment_by": "this_court"}, {"raw_citation": "(2004) 10 SCC 65", "case_name": "Amrendra Pratap Singh v. Tej Bahadur Prajapati & Ors.", "cited_year": "2004", "paragraph": "20, 33", "treatment": "referred", "treatment_by": "this_court"}, {"raw_citation": "(2008) 12 SCC 481", "case_name": "K.D. Sharma v. Steel Authority of India Limited & Ors.", "cited_year": "2008", "paragraph": "23", "treatment": "referred", "treatment_by": "this_court"}, {"raw_citation": "(2012) 6 SCC 430", "case_name": "A. Shanmugam v. Ariya Kshatriya Rajakula Vamsathu Madalaya Nandhavana Paripalanai Sangam represented by its President & Ors.", "cited_year": "2012", "paragraph": "23", "treatment": "referred", "treatment_by": "this_court"}, {"raw_citation": "(1964) 2 SCR 203", "case_name": "Hari Narain v. Badri Das", "cited_year": "1964", "paragraph": "23", "treatment": "referred", "treatment_by": "this_court"}, {"raw_citation": "(1917) 1 KB 486", "case_name": "Kensington Income Tax Commrs.", "cited_year": "1917", "paragraph": "23", "treatment": "referred", "treatment_by": "this_court"}]
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