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Issues: Whether Section 4(c) of the Consolidation of Holdings & Prevention of Fragmentation Act 1956, which transfers proceedings concerning land to the consolidation authorities and causes pending civil proceedings to abate, is violative of Articles 14 and 19 of the Constitution of India.
Analysis: The challenge to the provision was rejected. The provision was treated as operating to confer exclusive jurisdiction on the consolidation authorities in the covered matters and to bring pending civil proceedings to an end by abatement. The constitutional objections were not examined afresh because the point was already covered by earlier decisions of the Court, which the High Court had followed.
Conclusion: The provision was not held to be unconstitutional, and the petitions failed.
Ratio Decidendi: Where the Court has already upheld the statutory scheme, a challenge to the exclusive jurisdiction and abatement mechanism under the consolidation law does not succeed on Articles 14 and 19 grounds.