Purposive interpretation of land grant provisions limits benefits to landless agricultural labourers under the Bhoodan scheme.

The expression "landless persons" in Section 14 of the U.P. Bhoodan Yagna Act was construed purposively in light of the Bhoodan Yagna scheme under Section 15, rather than by a literal reading. Grants under the scheme were intended for landless agricultural labourers or bhoomihin kisan who depended on agriculture and had no land of their own. The amendment replacing "landless persons" with "landless agricultural labourers" reinforced that scope. As the respondents were businessmen, not agriculturists, and had property and income, they did not fall within the intended class, and cancellation of the allotments was justified.

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Issues: Whether the expression "landless persons" in Section 14 of the U.P. Bhoodan Yagna Act was to be construed literally so as to include the respondents, or whether it had to be read in the context of the scheme and purpose of Bhoodan Yagna under Section 15; and whether the Additional Collector was right in cancelling the grants made in favour of the respondents.

Analysis: The allotments were made to businessmen residing in Kanpur who were not agriculturists, had properties and income, and did not depend on agriculture for their livelihood. The Court held that the words "landless persons" in Section 14 could not be read in isolation or given a merely literal meaning. Section 15 required that grants be made in accordance with the Bhoodan Yagna scheme, and the scheme itself was directed to landless agricultural labourers or bhoomihin kisan who lived by agriculture and had no land of their own. The amendment substituting "landless agricultural labourers" in place of "landless persons" further confirmed the intended scope of the provision. On that construction, the respondents did not fall within the class of persons intended to receive grants, and the cancellation of the allotments was justified.

Conclusion: The expression "landless persons" in Section 14 was to be read purposively in light of the Bhoodan Yagna scheme, and the grants in favour of the respondents were not valid.

Ratio Decidendi: Where the language of a welfare statute is tied to a specific social movement or scheme, the operative expression must be construed in the light of the statute's purpose and scheme rather than by a purely literal meaning.

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