Title of the Case: HAR NARAINI DEVI & ANR Vs. UNION OF INDIA & ORS
Head Notes: Though, succession to an agricultural land is
otherwise dealt with under Section 22 of the Act, the
provisions of Section 4(2) of the Act, before its
omission, had made it clear that the provisions of
the Act would not apply in cases inter alia of
devolution of tenancy rights in respect of
agricultural holdings. Thus, the effect of Section
4(2) of the Act before its deletion was quite clear
that, though the general field of succession
including in respect of agricultural lands was dealt
with under Section 22 of the Act, insofar as
devolution of tenancy rights with respect to
agricultural holdings were concerned, the
provisions of Section 22 would be inapplicable. The
High Court of Bombay was, therefore, absolutely
right in its conclusion. However, with the deletion
of Section 4(2) of the Act, now there is no exception
to the applicability of Section 22 of the Act
