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Issues: Whether Section 170-B of the Madhya Pradesh Land Revenue Code, 1959 applied to transfers of agricultural land between members of aboriginal tribes, and whether the show-cause notice issued by the Sub-Divisional Officer was without jurisdiction.
Analysis: Section 170-B, as enacted in 1980, used broad expressions such as "every person", "any person" and "all such transactions of transfer", and its scheme contemplated collection of information followed by enquiry into whether the transferor had been defrauded of legitimate rights. The later insertion of sub-section (2-A) in 1998 could not be used to cut down the plain scope of the original provision. The statement of objects and reasons could explain the background but could not control clear statutory language. The provision was held to cover transfers even between tribals where the statutory conditions were attracted, and failure to furnish information did not by itself negate the need for enquiry under sub-section (3). The notice issued by the Sub-Divisional Officer therefore could not be treated as lacking jurisdiction.
Conclusion: Section 170-B was held applicable to the transaction in question, including intra-tribal transfers, and the notice initiating proceedings was valid.
Final Conclusion: The challenge failed because the statute was interpreted broadly on its plain language, and the appellant was required to participate in the enquiry instead of seeking immediate writ relief.
Ratio Decidendi: Where the language of a protective land-reversion provision is clear and unambiguous, its scope cannot be narrowed by the statement of objects and reasons or by later amendments, and the provision applies according to its plain terms.