Crystallised tenant purchase rights under land reform law survive the landlord's later death and devolution of title.

A tenant's right to purchase land under the Punjab Security of Land Tenures Act, 1953 becomes crystallised once the first instalment is deposited, because section 18(4) deems the tenant to have become owner at that stage. The relevant date for testing entitlement is when the purchase application is made and the statutory deposit is completed. A landlord's later death during appeal, and the resulting devolution of title, does not defeat rights already vested under the Act. Subsequent events may affect relief in some cases, but they cannot divest substantive rights that have accrued under a self-contained agrarian reform scheme.

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Issues: Whether a tenant's right to purchase land under the Punjab Security of Land Tenures Act, 1953, once acquired and crystallised by deposit of the first instalment, is defeated by the landlord's death during the pendency of appeal so that the heirs, having become small landowners, can resist the purchase.

Analysis: Under section 18(1), a tenant of a landowner other than a small landowner is entitled to purchase the land. Under section 18(4), upon deposit of the first instalment, the tenant is deemed to have become the owner. The statutory scheme fixes the relevant date for testing entitlement at the time the application is made and the statutory deposit is completed. Subsequent devolution of the landlord's interest during appeal does not undo rights already vested under the Act. The principle governing subsequent events may influence relief in appropriate cases, but it cannot be used to divest substantive rights that have already accrued under a self-contained agrarian reform statute.

Conclusion: The subsequent death of the landlord did not destroy the tenants' accrued right to purchase, and the appeal failed.

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