Broad meaning of interested parties: tenants in possession under a Gram Panchayat lease must receive notice before revision.

Tenants in actual possession under a Gram Panchayat lease are interested parties for revision under the proviso to Section 42 of the East Punjab Holdings (Consolidation and Prevention of Fragmentation) Act, 1948. The proviso requires notice and an opportunity of hearing before any variation or reversal of an order, and the expression "interested parties" is to be read broadly to include persons whose possession or legal rights may be affected by the revisional decision. Because the tenants' tenancy and possession could be materially impacted by the dispute between rival claimants and the Panchayat, failure to serve notice made the revisional order unsustainable.

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Issues: Whether tenants in possession of land leased by the Gram Panchayat are "interested parties" entitled to notice and a hearing before the State Government or its delegate exercises revisional power under the proviso to Section 42 of the East Punjab Holdings (Consolidation and Prevention of Fragmentation) Act, 1948 in a dispute concerning title between rival claimants and the Gram Panchayat.

Analysis: The proviso to Section 42 makes notice to interested parties and an opportunity of hearing a mandatory precondition to variation or reversal of orders passed under the Act. The expression "interested parties" is to be construed broadly and includes persons whose possession, tenancy rights, or other legal interests are likely to be affected by the decision. The legislation creates rights in favour of tenants as well as landholders in the course of consolidation proceedings, and a tenant in actual possession under a lease from the Panchayat cannot be treated as a stranger to the controversy merely because the substantive title dispute is between the proprietors and the Panchayat. The tenants' interests may be materially affected by the outcome, and denial of notice renders the revisional order unsustainable.

Conclusion: The tenants were entitled to be heard as interested parties, and the orders passed without notice to them were invalid.

Ratio Decidendi: Under the proviso to Section 42, any person whose possession or legal interest may be affected by the revisional decision is an interested party and must be given notice and an opportunity of hearing before an order varying or reversing the earlier decision is made.

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