Natural justice requires notice to transferees before surplus land is declared under agricultural land law.

A transferee from a landowner was held to be a person interested under the Pepsu Tenancy and Agricultural Lands Act, 1955, because transfers had to be disclosed in the statutory return and draft statement, and Section 32-FF preserved such transfers against the transferor and transferee while making them ineffective only against the State. Since proceedings to declare surplus area could directly affect the transferee's rights, including a possible claim under the proviso to Section 32-FF, natural justice applied even without an express notice provision. The transferee was therefore entitled to notice and an opportunity of hearing before the transferor's surplus area was declared.

---

---

Issues: Whether, under the Pepsu Tenancy and Agricultural Lands Act, 1955, a transferee from a landowner is a person interested entitled to notice and an opportunity of hearing before the surplus area of the transferor is declared.

Analysis: The statutory scheme required the landowner to disclose transfers in the return and in the draft statement, and Section 32-FF preserved transfers against the transferor and transferee while making them ineffective only against the State. The transferee could therefore have a direct and prejudicial interest in proceedings determining whether the transferred land formed part of the surplus area, including a possible claim under the proviso to Section 32-FF. The absence of an express rule for notice did not exclude the application of natural justice, and the principle of audi alteram partem applied to proceedings having civil consequences and quasi-judicial character.

Conclusion: The transferee is a person interested and must be given notice and an opportunity of hearing before the surplus area of the transferor is declared under the Act.

---