Reasonable-time limit for suo motu tenancy powers prevents belated invalidation of long-settled land transfers.

Section 84-C of the Bombay Tenancy and Agricultural Lands Act, 1948 does not prescribe a limitation period for suo motu action, but the power must still be exercised within a reasonable time. The text states that a transfer made in 1972 was questioned only after a substantial delay, and that belated invalidation would prejudice the purchaser. On that basis, the commentary concludes that delayed initiation of the suo motu enquiry was not a proper exercise of statutory power and the challenge to the sale deeds could not be sustained.

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Issues: Whether the suo motu power under Section 84-C of the Bombay Tenancy and Agricultural Lands Act, 1948 was exercised within a reasonable time.

Analysis: Section 84-C does not prescribe any limitation period for initiation of proceedings, but a statutory power conferred without an express time-limit must still be exercised within a reasonable time. The transfer had taken place in 1972 and the suo motu enquiry was initiated after a substantial lapse of time. In such circumstances, and where the purchaser would suffer prejudice from belated invalidation of the transaction, the power could not be treated as having been properly exercised.

Conclusion: The suo motu power under Section 84-C was not exercised within a reasonable time, and the challenge to the sale deeds could not be sustained.

Ratio Decidendi: Where a statute confers suo motu jurisdiction without prescribing a time-limit, the power must nevertheless be exercised within a reasonable time.

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