Govindappa Gounder @ Govindasamy (D) v. K. Vijayakumar 2025 INSC 1134 - Beneficent Construction Of Statutes - TN Cultivating Tenants Protection Act
Tamil Nadu Cultivating Tenants Protection Act, 1955 - The Act 1955 was enacted solely to protect the interest of the cultivating tenants. In other words, the object in enacting the said Act was to protect the cultivating tenants from forcible dispossession by the landlords. In such circumstances, the provisions of the Act should also be interpreted accordingly. In other words, the provisions should be interpreted in such a manner that the tenants are ultimately protected and are not thrown out at the instance of the landlords who are always interested to see that the tenants leave. It is only when there is cogent, credible and reliable evidence on record of gross violation of the provisions of Section 3(2)(b) of the Act 1955 that the Revenue Court may be justified in ordering eviction of the tenant under the Act 1955. (Para 22)
Interpretation of Statutes - Beneficent construction involves giving the widest meaning possible to the statutes. When there are two or more possible ways of interpreting a section or a word, the meaning which gives relief and protects the benefits which are purported to be given by the legislation, should be chosen. A beneficial statute has to be construed in its correct perspective so as to fructify the legislative intent. (Para 24) Courts should not allow themselves to become tools for defeating clearly expressed statutory intentions. (Para 23)
Case Info
Case Name and Neutral Citation
- Case Name: Govindappa Gounder @ Govindasamy (Dead) v. K. Vijayakumar & Ors.
- Neutral Citation: 2025 INSC 1134
Coram
- Justice J.B. Pardiwala
- Justice Sandeep Mehta
Judgment Date
- 10 September 2025
Caselaws and Citations
- G. Ponniah Thevar v. Nalleyam Perumal Pillai & Ors.Citation: (1977) 1 SCC 500
Statutes/Laws Referred
- Tamil Nadu Cultivating Tenants Protection Act, 1955
- Section 3 (Protection from eviction)
- Section 3(2)(b) (Exception for destructive/neglectful acts or ceasing cultivation)
- Section 6-B (Revision by High Court under Section 115 of CPC)
- Code of Civil Procedure, 1908
- Section 115 (Revision jurisdiction of High Court)
Q&A
Questions and Answers
1. What is the main subject of the Supreme Court judgment?
Answer:The judgment concerns the eviction of a cultivating tenant under the Tamil Nadu Cultivating Tenants Protection Act, 1955, and whether the tenant caused damage to the land justifying eviction.
2. Who are the parties involved in the case?
Answer:The appellant is Govindappa Gounder @ Govindasamy (Dead), represented by his legal heirs, and the respondents are K. Vijayakumar and others.
3. What was the original dispute about?
Answer:The dispute was about possession and cultivation rights over land in Village Pichanoor, Coimbatore, Tamil Nadu, and allegations of damage to the property by the tenant.
4. What did the Trial Court decide in Original Suit No. 1363/1993?
Answer:The Trial Court decreed that the landowners should not disturb or interfere with the lawful possession of the tenant except in accordance with law.
5. What relief was sought in Original Suit No. 491/1994?
Answer:The plaintiffs sought a permanent injunction restraining the defendants from cutting trees or causing damage to the property and also claimed damages for alleged loss.
6. What did the Revenue Court decide regarding the tenant?
Answer:The Revenue Court ordered eviction of the tenant, finding that he had cut trees, dug pits, and caused damage to the land, thus losing his tenancy rights under Section 3(2)(b) of the Act.
7. What is Section 3(2)(b) of the Tamil Nadu Cultivating Tenants Protection Act, 1955?
Answer:It allows eviction of a tenant who has done any act or been negligent in a way that is destructive or injurious to the land or crop, or has ceased to cultivate the land.
8. What did the Supreme Court conclude about the evidence of damage?
Answer:The Supreme Court found no cogent evidence that the appellants were negligent or caused substantial damage to the land, and pruning trees alone did not justify eviction under Section 3(2)(b).
9. What principle did the Supreme Court emphasize regarding interpretation of the Act?
Answer:The Court emphasized that the Act should be interpreted to protect cultivating tenants, and eviction should only occur with credible evidence of gross violation.
10. What was the final order of the Supreme Court?
Answer:The Supreme Court set aside the High Court and Revenue Court orders of eviction, restoring the tenant’s possession and directing that the respondents not interfere except in accordance with law.
