Successor-in-interest must intimate tenant of cessation of widow's interest to enable exercise of purchase right.

The petitioners are legal heirs of protected tenants (Kondu and Barku Patil) who occupied agricultural land (Gat No. 119, Domgaon) owned by Chindhu Pandu Wani

The landlord died in 1946, leaving two widows, Dwarkabai (d. 1981) and Nababai (d. 1994)

On the "Tillers’ Day" (01.04.1957), the tenants' right to purchase was postponed under Section 32-F of the Maharashtra Tenancy and Agricultural Lands Act because the landlords were widows

In 2001, the petitioners sought to fix the purchase price. The Tahsildar and Sub-Divisional Officer rejected the claim, citing the expiration of the limitation period for exercising the right of purchase after the deaths of the widows

The Maharashtra Revenue Tribunal (MRT) dismissed the revision on grounds of delay

The respondents claimed possession was already recovered in 2017

1. Whether the tenant’s right to purchase is forfeited if the landlord’s successors fail to give intimation of the cessation of the widow’s interest

2. Whether the petitioners are entitled to have the purchase price fixed under Section 32-F despite the lapse of the statutory period from the date of the landladies' deaths

Section 32-F of the Maharashtra Tenancy and Agricultural Lands Act, 1948, which governs the postponed right of purchase when a landlord is a widow, requiring the tenant to exercise the right within a specified period after the interest ceases

The Constitutional Bench decision of the Supreme Court in Vasant Ganpat Padave (D) by LRs. & Ors. vs. Anant Mahadev Sawant (D) (2020), which established that the successor-in-interest of a widow is under a mandatory obligation to intimate the tenant about the cessation of the widow’s interest to trigger the limitation period for purchase

The court reasoned that although the tenants’ right was postponed due to the landladies' widowhood, the clock for exercising the purchase right does not start automatically upon death

Applying the Vasant Ganpat Padave precedent, the court held that since the respondent-landlords provided no evidence of giving formal intimation to the tenants regarding the deaths of Dwarkabai and Nababai, the tenants cannot be precluded from seeking fixation of the purchase price

The court dismissed the respondents' arguments regarding limitation and the alleged recovery of possession, noting that the statutory obligation of the landlord to provide intimation is a prerequisite for the expiry of the tenant's right

The court held that in the absence of intimation from the landlords, the tenants’ right remains exercisable. It directed the authorities to proceed with the determination of the purchase price under the Act

Rule was made absolute