Surplus land liability under ceiling law survives the holder's death before declaration; proceedings continue against the estate.

Liability to surrender surplus land under the Maharashtra Agricultural Lands (Ceiling on Holdings) Act, 1961 attaches to the holding on the statutorily relevant date, not on the later publication of the section 21 declaration or taking of possession. Proceedings for determination of surplus land therefore do not abate or become infructuous merely because the holder dies before declaration. The Act's object of equitable distribution would be frustrated if death could defeat proceedings already commenced, and the later amendment requiring death to be ignored before declaration was treated as declaratory of the existing position. Heirs may participate for the estate, but the surplus liability remains attached to the holding.

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Issues: Whether proceedings initiated under the Maharashtra Agricultural Lands (Ceiling on Holdings) Act, 1961 for determination of surplus land abate or become infructuous on the death of the holder before publication of the declaration under section 21.

Analysis: The liability to surrender surplus land under the Act is determined with reference to the appointed day or other relevant statutory date under section 12, and not by the later date on which the declaration under section 21 is published or possession is taken. The scheme of the Act treats the holding as the relevant unit, and the statutory object of equitable distribution of land would be frustrated if death before declaration were allowed to defeat proceedings already commenced. The later amendment inserting an express direction to ignore death before declaration was treated as declaratory of the pre-existing legal position. The heirs of the deceased holder may participate in the proceedings representing the estate, but they cannot claim the holding free from the surplus liability already attached to it.

Conclusion: The proceedings did not abate on the holder's death, and the surplus land had to be determined and dealt with in accordance with the Act; the appeal was therefore without merit.

Ratio Decidendi: Under the Act, liability for surrender of surplus land attaches to the holding on the statutorily relevant date and survives the holder's death before declaration under section 21; death does not render the ceiling proceedings infructuous.

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