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Issues: Whether land entered in the revenue records and mainly used for agriculture could be excluded from "vacant land" under Section 2(o) of the Urban Land (Ceiling and Regulation) Act, 1976 where it was shown in a master plan prepared after the commencement of the Act.
Analysis: The Act fixed rights and liabilities on the date of its commencement in the State, and the determination of excess vacant land was only a quantification exercise thereafter. Explanation (C) to Section 2(o) was construed in the context of the scheme of the Act to mean that the relevant master plan must be one existing at the time of commencement of the Act. A later master plan could not alter the character of land for the purpose of enlarging the excess vacant land by reference to a subsequent event. The land in question satisfied the requirements of agricultural use and revenue entry, and the later master plan could not defeat that position.
Conclusion: The land could not be treated as non-agricultural by reason of the master plan prepared after the Act came into force, and the District Judge's order reducing the excess vacant land was restored.