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Issues: Whether the petitioners could be deprived of the school land and building, held by them as trustees for the school, and whether the impugned directions under the Bihar Education Code had the force of law so as to justify interference with their possession and management.
Analysis: The petitioners were treated, on the admitted facts, as proprietors of the land and building only in a trustee capacity for the purposes of the school. The governing question was whether they had been divested of that interest by authority of law within the meaning of Article 31(1) of the Constitution. The Bihar Education Code provision relied upon by the respondents was found to be no more than an administrative direction, lacking statutory backing and therefore lacking the force of law within Article 13. In the absence of lawful authority, the State could not take over possession or interfere with the petitioners' rights in the school property.
Conclusion: The petitioners' property rights could not be interfered with except by authority of law, and the impugned action was unauthorised and invalid.
Ratio Decidendi: A person holding property as trustee cannot be deprived of that property by executive directions lacking statutory force; interference with such rights is valid only when supported by law.