HON’BLE SUPREME COURT · SOURCE-REVIEWED NOTE
Collector of Sultanpur and Another v. Raja Jagdish Prasad Sahi
Civil Appeal No. 1014 of 1963
[1965] 2 SCR 29 ·
U.P. Agricultural Income-tax Act, 1949: sections 3 and 31 · U.P. Zamindari Abolition and Land Reforms Act, 1951: section 6(d) · U.P. Zamindari Abolition and Land Reforms Rules: rule 8-A
Sources & disclosures includedDownload original judgment / order
Three-judge bench; judgment delivered by J. C. Shah, J. · K. Subba Rao, J. · J. C. Shah, J. · S. M. Sikri, J.
Assessment years: Fasli year 1359 (1 July 1951 to 30 June 1952)
01 · Facts of the case
Agricultural income-tax assessed for the period ending 30 June 1952 was pursued by coercive recovery. The respondent sought adjustment against compensation bonds for the vested zamindari; the High Court directed adjustment, but the record did not establish whether bonds remained to be delivered (SCR pp.29-32; PDF pp.1-4).
02 · Discussion by the Hon’ble Court
Rule 8-A imposed a mandatory duty to adjust qualifying agricultural income-tax against compensation; its “without prejudice” opening preserved other recovery rights rather than creating discretion. Because section 3 charged the previous year’s income, the tax related to the pre-vesting period and fell within section 6(d) (SCR pp.32-34; PDF pp.4-6).
03 · Judicial decision
The Court set aside the High Court’s operative order and remanded for determination of whether compensation bonds remained and, if not, whether another appropriate direction could make the adjustment effective. No costs were ordered.
Source: Primary judgment: remand order
04 · Outcome / in whose favour
Legal issue in favour of the respondent, with the ultimate relief left to a factual remand.
05 · AKHB REVIEW POINT
AKHB analysis: distinguish the mandatory adjustment rule from the factual availability of the fund or instrument against which adjustment can operate. The legal win did not eliminate the need to prove an effective source of satisfaction.
Source & verification
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Statutory scope
Historical Uttar Pradesh agricultural income-tax and zamindari-compensation regime. The judgment’s legal rule and remand do not establish any present adjustment entitlement.
Later treatment
Source checked 2026-10-12. No comprehensive current-law or later-treatment clearance is represented.
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