Reasonable time limits constrain restoration powers under tenancy law, and non-retrospective provisions cannot invalidate earlier transactions.

Section 71A of the Chota Nagpur Tenancy Act gives a protective power to restore land to Scheduled Tribe members where transfer was unlawful or fraudulent, but the phrase "at any time" does not permit indefinite or arbitrary use. The power is not governed by the Limitation Act, yet it must be exercised within a reasonable time, especially where third-party rights have arisen. The Court also noted that section 46, which came into force in 1948, could not be applied retrospectively to a 1938 surrender and settlement. The restoration order was therefore unsustainable because the power was invoked after an unreasonable delay and against a transaction beyond the provision's temporal reach.

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Issues: Whether restoration of land under section 71A of the Chota Nagpur Tenancy Act, 1908 could be ordered after an inordinate delay in respect of a 1938 transaction, and whether the absence of a specific period of limitation under the provision permitted exercise of the power after forty years.

Analysis: Section 71A confers a protective, enabling power on the Deputy Commissioner to restore possession to members of Scheduled Tribes where land has been transferred unlawfully or by fraud. The expression "at any time" does not authorise an indefinite or arbitrary exercise of that power; it must be read contextually and within a reasonable time. A statutory limitation period under the Limitation Act does not govern such restoration proceedings, but the power cannot be invoked after an unreasonably long delay, especially where third-party rights have intervened. The Court also noted that section 46 of the Act had come into force only in 1948 and therefore had no retrospective application to a 1938 surrender and settlement.

Conclusion: The restoration order was unsustainable because the power under section 71A was exercised after an unreasonable lapse of time, and the 1938 transaction could not be tested by a provision that had no retrospective effect.

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