Statutory purchase on tillers' day ends landlord-tenant status and voids later eviction and transfer proceedings.

Under the Bombay Tenancy and Agricultural Lands Act, 1948, a tenant is treated as the deemed purchaser on the tillers' day where the landlord is not under any statutory disability, and the landlord's interest then stands extinguished. Section 32-F applies only if the landlord is a minor, widow, or otherwise under mental or physical disability on that date, so it cannot postpone purchase in other cases. Proceedings based on the mistaken assumption that the tenancy continued after statutory purchase are void for want of jurisdiction, and eviction or transfer orders founded on such an error cannot stand. Where the sale by the recorded owner is ineffective, transferees acquire no title and restoration of possession to the tenant's heir is supportable.

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Issues: Whether the tenant had become the deemed purchaser of the land on the tillers' day under the Bombay Tenancy and Agricultural Lands Act, 1948, so that subsequent proceedings treating the sale as postponed under Section 32-F and the eviction and transfer orders based on a continuing landlord-tenant relationship were without jurisdiction and whether the respondent was entitled to restoration of possession.

Analysis: Section 32 brought about a statutory purchase in favour of every tenant on 1 April 1957 where the landlord was under no disability. Once that statutory event occurred, the landlord's interest stood extinguished and the landlord-tenant relationship came to an end. On the facts found, the landlord was alive and under no disability on the tillers' day, so the tenant became the deemed purchaser by operation of law. Section 32-F had no application, because it postpones the date of purchase only where the landlord is a minor, widow, or person under mental or physical disability on the tillers' day. Any later proceedings proceeded on a mistaken assumption that the tenant was still a tenant and the recorded owner could defer the purchase. Such proceedings were founded on an erroneous jurisdictional fact and were therefore void. The eviction proceedings under Sections 14 and 29 also failed, because there was no subsisting landlord-tenant relationship after the statutory purchase, and the transferees derived no title from the void sale by the recorded owner. The order restoring possession to the tenant's heir was consequently sustained.

Conclusion: The tenant had become the deemed purchaser on the tillers' day, the later proceedings were void for want of jurisdiction, and the order restoring possession to the respondent was upheld.

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