Reviewed case brief
State of Bihar v Kameshwar Singh
AIR 1952 SC 252
The Supreme Court examined the Bihar Land Reforms Act 1950 which abolished the zamindari system in Bihar. While upholding the legislative competence to abolish zamindari, the Court struck down certain provisions relating to compensation as being illusory, establishing that compensation must bear som
- Court
- Supreme Court of India
- Year
- 1952
- Subjects
- Land Laws
- Reviewed
- 2026-06-18
Rule established
Zamindari abolition laws providing for compensation on principles laid down by the legislature are valid; the court will not substitute its own view of adequacy of compensation
Facts
- The Bihar Legislature enacted the Bihar Land Reforms Act 1950 to abolish the zamindari system
Issues
Held
- The legislature has the **competence to abolish zamindari** as a measure of agrarian reform
Ratio decidendi
The legislature's power to abolish zamindari and acquire estates is valid, but the requirement of "compensation" under Article 31(2) imposes a minimum threshold: the amount must not be so derisory as to be illusory. While full market value is not constitutionally mandated, the principles laid down must yield some reasonable relationship to the value of the property taken. The judiciary retains power to examine whether what is provided qualifies as "compensation" in the legal sense.
How to use it in an exam
- Deploy for the pre-Fourth Amendment position on justiciability of compensation
Editorial source
AIR 1952 SC 252; verified via SCC Online
Educational summary only. Read the reported judgment or an authorised law report before relying on the case professionally.