Any Jaw providing for the acquisition b)' the State of an 'estate' is saved by art 3 lA subject to certain conditions, violation of arts. 14, 19 and 31 notwithstanding. Sub-article (2) explains the concept of 'estate' and includes therein janrnam rights. Although art. 31A is worded widely enough to rope in acquisition of any estate B by the State regardless of purpose, the Supreme Court has cut back on this amplitude by limiting entitlement to constitutional protecnon to agrarian reform legislation only. Subba Rao, J., in Kochuni's(1 ) ease, speaking for the Court, reviewed the earlier decisions under art· 3 JA and interpreted the provision against the back-drop of the Objects of the Constitution lForth Amendment) Act, 1955 and c the earlier Constitution (First Amendment) Act, 1951, to arrive at the conclusion that art. 3 lA was meant "to facilitate agranan reforms". Thls Court in the aforesaid decision struck down the Madras Marurnakkathayarn (Removal of Doubts) Act, 195:!, because "the impugned Act does not effectuate any agrarian reforms and regulate the· rights inter-se between landlords and tenants." D Art. 3 lA deprives citizens of their fundamental rights and such an article cannot be extended, by interpretation, to overreach the object implicit in the article, observed Subba Rao, J., and this judicial gloss has come to stay· Forensic debate has since centred round what is agrarian reform, and counsel here have joined issue on the claim E of the Forest Act to wear this protective IJlantle.
