Land laws in India constitute a comprehensive legal framework governing land ownership, use, transfer, and revenue administration, integrating constitutional provisions, central legislation, and state-specific laws. These laws address diverse aspects including land acquisition, reforms, forest rights, registration, and revenue collection, while balancing economic development, social justice, and environmental conservation. The framework encompasses both traditional systems and modern reforms, particularly exemplified in the Madhya Pradesh Land Revenue Code of 1959 and various other significant legislations that collectively shape India's land administration and management system. 

Introduction
Land laws in India regulate the ownership, use, and transfer of land, playing a pivotal role in governance, economic development, and social justice. They derive their authority from a combination of constitutional provisions, state legislations, and central laws.

Key Legislative Framework:

• Land Acquisition Rehabilitation and Resettlement Act, 2013
  • The Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 ensures fair compensation for acquired land.
  • Mandates social impact assessment and consent requirements.
  • Provides rehabilitation and resettlement provisions for affected families.
  • Restricts acquisition of multi-crop land.
     
• Land Reforms Acts (State-specific):
  • Abolished intermediary systems like Zamindari.
  • Implemented land ceiling limits.
  • Provided protection to tenants.
  • Enabled consolidation of landholdings.
     
• Forest Rights Act, 2006:
  • Recognizes forest-dwelling communities' rights.
  • Provides framework for sustainable forest management.
  • Protects traditional forest dwellers' interests.
     
• Registration Act, 1908:
  • Mandates registration of land-related documents.
  • Maintains records of land transactions.
  • Prevents fraudulent property transfers.
     
• Transfer of Property Act, 1872:
  • Governs the transfer of property between living persons, ensuring legality and clarity in transactions.
  • It applies to immovable property, including sale, mortgage, lease, gift, and exchange, and defines conditions for valid transfers.
  • The Act provides essential legal concepts, including property rights, actionable claims, and vested or contingent interests.
  • Exclusions under the Act include transfers governed by succession laws, insolvency laws, and transfers by operation of law.
     

Key Features of Land Laws

• Ownership and Transfer: Land laws govern the rights of individuals and entities over land, including sale, lease, inheritance, and mortgage. Important legislations include the Transfer of Property Act, 1882 and the Indian Registration Act, 1908.
• Agricultural Land: Laws regulate the use and ownership of agricultural land, focusing on equitable distribution and prevention of concentration of landholdings. Examples include state-specific land ceiling acts and tenancy laws.
   
• Urban Land: Urban land use and development are governed by laws like the Urban Land (Ceiling and Regulation) Act, 1976 (now repealed) and municipal laws. These address zoning, planning, and development.
   
• Tribal and Forest Land: Specific laws protect tribal communities and their rights over forest land, such as the Scheduled Tribes and Other Traditional Forest Dwellers (Recognition of Forest Rights) Act, 2006.
   
• Land Acquisition: The Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 governs land acquisition for public purposes, ensuring fair compensation and rehabilitation for affected parties.
   
• Land Revenue and Records: State-specific revenue laws, like the Indian Land Revenue Act, 1873, ensure proper maintenance of land records and collection of revenue.
   

• Significance:
  • Economic Growth: Land is a critical resource for infrastructure, industry, and agriculture, directly impacting India's economic progress.
  • Social Justice: Equitable land distribution is vital for reducing poverty and addressing social inequalities, particularly for marginalized communities.
  • Environmental Conservation: Proper regulation of land use supports sustainable development and environmental conservation.
  • Dispute Resolution: Comprehensive land laws and records help reduce disputes and ensure clear land titles, critical for legal and economic stability.
     
• Madhya Pradesh Land Revenue Code, 1959
  • The Madhya Pradesh Land Revenue Code, 1959 (MPLR Code) is a comprehensive legislation consolidating and amending laws related to land revenue, tenures, and agricultural land in Madhya Pradesh. It serves as the foundational framework for land administration, aiming to simplify and standardize land-related processes across the state.
     
• Key Objectives of the MPLR Code:
  • Uniform Land Administration: To create a unified system for land revenue, tenures, and management.
  • Regulation of Land Rights: To clearly define the rights and responsibilities of landholders.
  • Protection of Tenants and Farmers: To safeguard the interests of tenants, cultivators, and marginalized communities.
  • Revenue Collection: To streamline the collection of land revenue and other dues.
  • Dispute Resolution: To provide a legal framework for resolving land disputes efficiently.

Key Provisions of the MPLR Code, 1959

• Revenue Officers and Organization: The code establishes a comprehensive hierarchy of revenue officers, defining their specific powers and duties while creating a structured system of revenue divisions and subdivisions. It also establishes revenue courts to handle land-related disputes and administrative matters.
   
• Land Records Management: The code implements a systematic approach to maintaining land records through Khasra and Khatauni, documenting rights and interests in land while establishing clear procedures for record updates and conducting survey and settlement operations.
   
• Classification of Land Rights: Under the code, land is categorized into various types including government land (Nazul), private land (Bhumiswami), common lands, and forest lands, each with its distinct legal status and management requirements.
   
• Revenue Assessment: The code outlines comprehensive procedures for revenue assessment, including methods for fixing land revenue, collection procedures, and provisions for assessment revision to ensure fair and systematic revenue collection.
   
• Rights and Responsibilities: This section defines the rights of Bhumiswami, establishes occupancy rights, sets transfer restrictions, and implements land use regulations to ensure proper land management and protection of rights.
   
• Dispute Resolution: The code establishes detailed revenue court procedures along with appeal mechanisms, review provisions, and methods for executing orders, ensuring a robust system for resolving land-related disputes.
   
• Land Protection: The legislation implements measures to prevent land fragmentation, protect agricultural land, enforce conservation measures, and prevent encroachment, ensuring sustainable land use and protection.
   
• Special Provisions: The code includes specific measures for tribal land protection, management of common lands, administration of government lands, and conservation of forest lands, addressing unique needs of different land categories.
   

• Impact and Significance: The MPLR 1959 has established a systematic approach to revenue administration while protecting land rights, facilitating agricultural development, maintaining accurate revenue records, and providing an effective dispute resolution mechanism.
   
• Important Cases:
  • Chhote Lal v. State of Madhya Pradesh (1984 MPLJ 623): Concerned the consolidation of land holdings under the Madhya Pradesh Land Revenue Code and the protection of tribal landowners. The court upheld the rights of tribal landowners, ruling that transfers in violation of provisions protecting tribal lands are void and can be annulled under MPLRC.
     
  • State of Madhya Pradesh v. Shankar Lal (1994 MPLJ 301): Dealt with tenancy rights and land revenue disputes under MPLRC, particularly addressing the protection of tenants from unlawful evictions. The court reinforced the tenant's rights and ruled that eviction without following the due procedure under the MPLRC is invalid.
     
  • Nandu v. State of Madhya Pradesh (2000 AIR SC 1043): Concerned the Madhya Pradesh Land Revenue Code's provisions on surplus land distribution and the rights of landless laborers to be allotted surplus land. The court emphasized the socio-economic intent of land ceiling laws and directed the state to ensure fair and equitable distribution of surplus land to eligible beneficiaries.
     
• Madhya Pradesh Ceiling on Agricultural Holdings Act, 1960
  • Ceiling Limits: The Act established different ceiling limits for different types of land based on factors such as irrigation, fertility, and cropping patterns.
  • Acquisition of Surplus Land: Landholdings exceeding the ceiling limits were subject to acquisition by the government.
  • Compensation: Landowners were entitled to compensation for the acquired land, although the exact amount varied depending on the circumstances.
  • Distribution of Land: The acquired land was to be distributed to landless farmers and other eligible beneficiaries.
  • Implementation: The Act established a mechanism for the identification of surplus land, its acquisition, and its distribution.
     
• Exempted Land:
  • Land used for non-agricultural purposes: This includes land used for residential, industrial, commercial, or other non-farming purposes.
  • Land used for specific purposes: Land used for religious institutions, public utilities, educational institutions, and other specified purposes was generally exempt.
  • Land held by certain institutions: Land held by government institutions, educational institutions, and charitable trusts was often exempt.
  • Land held by certain individuals: In some cases, land held by individuals who were deemed to be engaged in specific activities, such as research or education, might be exempt.

 

1. Raghunath Gajadhar v. State of Madhya Pradesh (1975 AIR 1331)
   • Relevance: The case dealt with the interpretation of provisions under the Madhya Pradesh Ceiling on Agricultural Holdings Act regarding the computation of surplus land and whether certain exemptions applied to ancestral properties.
   • Judgment: The court clarified the ceiling limits and ruled that any land exceeding the prescribed limits, irrespective of ancestral claims, must be declared surplus.
      
2. K.K. Puri v. State of Madhya Pradesh (1989 SCC (2) 430)
   • Relevance: Focused on the Madhya Pradesh Ceiling Act, this case examined exemptions for land held for non-agricultural purposes and whether such lands should be excluded from ceiling calculations.
   • Judgment: The court ruled that land used exclusively for industrial or residential purposes cannot be considered agricultural and is thus exempt from ceiling limits.
      

Alluvion Land

Alluvion land refers to the land formed by the gradual deposition of soil or sediment by a river, stream, or other water bodies. This process, known as accretion, increases the land area of an adjoining property.

• Gradual Process: The formation occurs slowly over time.
• Ownership: The newly formed land generally belongs to the owner of the adjacent land, subject to local laws.
• Legal Basis: Governed by property and revenue laws, such as the Transfer of Property Act, 1882, and local land revenue codes.
• Examples: Land added along the banks of a river due to seasonal sedimentation.
   

Diluvion Land

Diluvion land refers to the land that has been eroded or washed away by the action of water bodies such as rivers, seas, or streams. This process, called erosion, leads to a reduction in the land area of an adjoining property.

• Gradual Loss: The loss of land happens over time due to natural forces.
• Ownership: The eroded land ceases to exist as a property of the original owner unless it reappears through accretion.
• Legal Basis: Similar to alluvion, local laws govern the implications of land loss.
• Examples: A portion of farmland lost to a river due to a change in its course.

Distinction Between Alluvion and Diluvion Land

Aspect	Alluvion Land	Diluvion Land
Definition	Formation of land due to soil deposition.	Loss of land due to erosion or washing away.
Process	Accretion (addition of soil or sediment).	Erosion (removal or washing away of soil).
Impact on Landowner	Increases land area for the adjoining owner.	Decreases land area for the adjoining owner.
Legal Implications	Ownership extends to the newly formed land.	Ownership is lost unless the land reappears.
Examples	Riverbank expansion due to sedimentation.	Riverbank loss due to flooding or erosion.

 
Diversion of Land
Diversion of land refers to the change in the intended use of agricultural land to a non-agricultural purpose, such as residential, commercial, or industrial use. It is a formal process governed by land revenue laws, ensuring that such a change in land use complies with legal requirements and does not adversely affect agricultural land availability or revenue.

Procedure of Land Diversion under MPLRC
Under the Madhya Pradesh Land Revenue Code (MPLRC), 1959, land diversion is regulated to ensure proper management of land resources and to prevent unauthorized conversions.

• Application: The landowner must submit an application to the designated authority (usually the Sub-Divisional Magistrate or Tehsildar) seeking permission to divert the land.
• Application Details: The application should include:
  • Detailed information about the land (location, area, current use, etc.)
  • Proposed use of the land after diversion
  • Supporting documents (e.g., land records, site plan, environmental impact assessment, if required)
     
• Scrutiny and Inspection: The concerned authority will scrutinize the application and may conduct an inspection of the land to assess the feasibility and impact of the proposed diversion.
• Public Notice: A public notice may be issued to inform local residents and gather their opinions or objections.
• Decision Making: Based on the application, inspection report, and public feedback, the competent authority will decide whether to grant or deny permission for land diversion.
• Conditions and Restrictions: If permission is granted, it may be subject to certain conditions and restrictions, such as:
  • Environmental safeguards
  • Development charges
  • Restrictions on certain types of construction
• Appeal: If the landowner is dissatisfied with the decision, they may have the right to appeal to a higher authority.

Lease

A lease is a legal agreement where a property owner (the "lessor" or "landlord") grants the right to use their property to another person (the "lessee" or "tenant") for a specific period in exchange for rent or other consideration. In the context of land laws, a lease transfers possession of land without transferring ownership. The governing provisions for leases in India are primarily under: Transfer of Property Act, 1882 (Sections 105–117) and State-specific Land Revenue or Tenancy Acts, which regulate agricultural leases.

Conditions under which a Bhumiswami can Lease his Land

A Bhumiswami is a legal term, often used in Indian land revenue laws (e.g., Madhya Pradesh Land Revenue Code, 1959), referring to a person who holds absolute rights over land. However, these rights are subject to certain restrictions when leasing land. A Bhumiswami (landowner) can generally lease their land under the following conditions:

• Legal Capacity: The Bhumiswami must be legally competent to enter into a contract. This means they must be of legal age and sound mind.
• Ownership Rights: The Bhumiswami must have clear and valid ownership rights over the land they intend to lease.
• Legal Purpose: The lease must be for a lawful purpose and not violate any applicable laws or regulations.
• Consent: The lease must be entered into voluntarily by both the Bhumiswami and the lessee.
• Terms and Conditions: The lease agreement must clearly define the terms and conditions of the lease, including:
  • Lease Term: The duration of the lease (e.g., 1 year, 5 years, etc.)
  • Rent: The amount of rent to be paid, the frequency of payment, and any applicable late fees.
  • Use of the Land: The permitted uses of the land (e.g., agricultural, residential, commercial).
  • Maintenance Responsibilities: Who is responsible for maintaining the property.
  • Renewal Options: Whether the lease can be renewed and under what conditions.
  • Dispute Resolution: How disputes between the lessor and lessee will be resolved.

Important Considerations

• Land Laws: The specific laws and regulations governing land leases vary by jurisdiction. It is essential to consult with legal counsel to ensure compliance with all applicable laws.
• Contractual Obligations: Both the lessor and lessee are bound by the terms of the lease agreement. Failure to comply with the terms can have legal consequences.
• Registration: Depending on the jurisdiction and the duration of the lease, it may be necessary to register the lease agreement with the relevant authorities.

Occupancy Tenant

An occupancy tenant is a tenant who has acquired certain rights over the land they occupy, often through long-term possession and cultivation. These rights can be significant and may even approach ownership rights, depending on the specific laws and regulations in place.

How an Occupancy Tenant Can Acquire Bhumiswami Rights

The process of an occupancy tenant acquiring Bhumiswami (landowner) rights can vary depending on the specific legislation governing land tenancies in the region. However, some common pathways include:

• Land Reforms: Land reform laws in India often provide mechanisms for occupancy tenants to acquire ownership rights over the land they cultivate. This may involve processes like land consolidation, redistribution, and the conversion of tenancy rights into ownership rights.
• Adverse Possession: Under certain conditions, an occupancy tenant who has been in continuous and exclusive possession of the land for a specified period (often 12 years or more) may be able to acquire ownership rights through adverse possession. This doctrine recognizes the principle that long-term, uninterrupted possession can establish ownership rights.
• Government Schemes: Some government schemes may provide incentives or assistance to occupancy tenants to acquire ownership rights over the land they cultivate.

Exempted Properties from Revenue Recovery

In India, certain properties are exempt from revenue recovery, attachment, and sale under land revenue or recovery laws. These exemptions ensure that essential resources and livelihood necessities of individuals are protected. The specific provisions may vary slightly under different state land revenue codes, but the general principles are derived from laws such as the Code of Civil Procedure, 1908 (Section 60) and various state-specific land revenue laws.

Properties Exempt from Revenue Recovery Attachment and Sale

• Essential Tools and Equipment: Tools of artisans, implements of husbandry, and tools necessary for agricultural operations. Livelihood tools essential for a person's trade or profession are exempt to ensure continued income generation.
• Residential Buildings: Houses and homesteads of small farmers, along with the land attached to them, are often exempt to prevent homelessness. In some states, this exemption applies only to properties used as primary residences.
• Standing Crops: Standing crops, which are essential for the livelihood of the landowner, cannot be attached or sold.
• Livestock: Livestock essential for agriculture, such as bullocks, cows, and plough animals, are exempt.
• Grain and Seeds: Grain stores and seeds required for the next agricultural cycle are protected from attachment to ensure continuity of farming.
• Clothing and Basic Necessities: Personal clothing, bedding, and necessary household items are exempt from attachment under recovery laws.
• Religious or Sacred Property: Properties dedicated to religious or charitable purposes, such as temples, mosques, churches, or other places of worship, are exempt.
• Wages and Salaries: Salaries of public servants or workers, up to a specific minimum threshold, are protected from recovery.
• Pension and Provident Fund: Pensions, gratuities, and provident funds, as protected under laws like the Pensions Act, 1871, cannot be attached.
• Land of Marginal Farmers and Scheduled Tribes: Lands held by marginal farmers, small landholders, or members of Scheduled Tribes in tribal areas are protected to safeguard their socio-economic rights. Special provisions often prevent alienation of tribal land even under recovery laws.
   

Relevant Legal Provisions

• Code of Civil Procedure, 1908 (Section 60): Provides a list of properties exempt from attachment and sale during the execution of a decree.
• State-Specific Land Revenue Codes: For example, the Madhya Pradesh Land Revenue Code, 1959 and the Rajasthan Land Revenue Act, 1956 have detailed provisions for exemptions.
• Special Laws: Laws like the Scheduled Tribes and Other Traditional Forest Dwellers (Recognition of Forest Rights) Act, 2006 protect tribal lands from attachment and sale.

Revenue Officers

Revenue officers play a vital role in administering land revenue, maintaining records, and resolving disputes in India. Their hierarchy and responsibilities are defined by state-specific land revenue laws, such as the Madhya Pradesh Land Revenue Code, 1959, and they ensure efficient revenue collection and land management.

1. Village-Level Revenue Officers
   • Patwari (or Lekhpal): The lowest-level revenue officer responsible for maintaining village-level land records. Duties include land measurement, updating records of rights, and assisting higher authorities in revenue collection and dispute resolution.
      
2. Tehsil-Level Revenue Officers
   • Naib Tehsildar: Assists the Tehsildar in managing tehsil-level land administration and revenue collection. Naib Tehsildar handles minor revenue disputes and oversees the work of Patwaris.
   • Tehsildar: The primary revenue officer at the tehsil level responsible for revenue collection, land record maintenance, and dispute resolution. He has quasi-judicial powers to handle land revenue cases and grant permissions for land transfers.
      
3. District-Level Revenue Officers
   • Sub-Divisional Officer (SDO): Supervises the work of Tehsildars and Naib Tehsildars within a sub-division of a district. SDO handles appeals against orders of Tehsildars and acts as an appellate authority for certain cases.
      
   • Collector (or District Magistrate): The highest revenue officer in the district, responsible for overseeing land revenue administration, land acquisition, and enforcement of land laws. Acts as the appellate authority for orders passed by subordinate revenue officers.
      
4. Divisional-Level Revenue Officers
   • Divisional Commissioner: Supervises revenue administration across multiple districts within a division. Acts as an appellate authority for orders passed by district Collectors and handles major revenue disputes.
      
5. State-Level Revenue Officers
   • Board of Revenue: The apex body for land revenue matters in the state, consisting of senior revenue officers. It acts as the final appellate authority for cases related to land revenue, tenancy, and land disputes. Members of the Board are experienced senior officers or judicial members with expertise in land laws.

 Appointment and the Power of the Divisional Commissioner: The Divisional Commissioner in India is a senior administrative officer appointed by the State Government. They are responsible for overseeing the administration of a division, which comprises several districts.

1. Appointment of Divisional Commissioner: The Divisional Commissioner is a senior administrative officer appointed by the state government to oversee the administration of a division, which is an administrative unit comprising several districts. The post is usually held by a senior officer from the Indian Administrative Service (IAS). The appointment is made based on seniority, experience, and competence.
2. Role of the Divisional Commissioner: The Divisional Commissioner acts as a link between the state government and the district administration. They supervise, coordinate, and support district collectors and other officials to ensure effective governance and implementation of government policies.
    
3. Powers and Functions of the Divisional Commissioner:
   • Administrative Powers:
     • Supervisory Role: The Commissioner oversees the work of district collectors and ensures proper implementation of government policies, schemes, and programs.
     • Law and Order: They supervise the law and order situation in the division, coordinating with district magistrates and police authorities.
     • Public Grievances: The Commissioner addresses grievances of citizens related to administration, ensuring redressal at the divisional level.
   • Revenue Powers:
     • Revenue Collection: They supervise land revenue administration, including collection, land records maintenance, and settlement operations.
     • Appellate Authority: The Commissioner serves as an appellate authority for decisions made by subordinate revenue officials, such as district collectors.
     • Land Reforms: They implement land reforms and oversee matters related to tenancy, land distribution, and agricultural land use.
   • Developmental Functions:
     • Coordination of Development Programs: The Commissioner monitors and evaluates the execution of developmental programs and welfare schemes in the division.
     • Infrastructure Development: They ensure proper implementation of infrastructure projects, such as roads, irrigation, and public utilities.
     • Disaster Management: The Commissioner plays a critical role in disaster management, coordinating relief and rehabilitation efforts during natural calamities.
   • Judicial and Quasi-Judicial Powers: The Commissioner exercises quasi-judicial powers in matters of revenue disputes, appeals, and revisions under various state laws.
      
4. Priority of Government Revenue Claim: The concept of "Revenue as the first charge on land" signifies that the government's claim for land revenue takes precedence over all other claims or debts against the land. This means that if a landowner defaults on their land revenue payments, the government has the right to recover the dues even before other creditors, such as banks or individuals.
    
5. Revenue Survey in Non-Urban Areas: Revenue Survey is a comprehensive process of collecting and recording detailed information about land in non-urban areas. This includes:
   • Mapping and demarcation of land boundaries: Accurate maps and records are created to define the exact boundaries of each land parcel.
   • Classification of land: Land is categorized based on its use, fertility, and other relevant factors.
   • Assessment of land revenue: The revenue payable to the government is determined based on the land's classification and other factors.
   • Recording of land ownership and rights: Details about the owners of the land and their rights are recorded.
   • Resource Management: Facilitating planning for agricultural productivity and rural development.
      
6. Process:
   • Preliminary Notification: The government notifies the area to be surveyed.
   • Measurement and Mapping: Land parcels are measured and mapped using modern techniques like GIS and traditional methods.
   • Verification and Classification: Details of ownership, type of land, and its usage are verified and classified.
   • Record Preparation: Survey results are compiled into land records such as village maps, RoR, and cadastral maps.
   • Publication: Finalized records are published for public review and objections, if any.
      
7. The Revenue Survey: The Revenue Survey is crucial for efficient land administration, revenue collection, and dispute resolution. It provides a reliable basis for various land-related transactions and helps ensure equitable distribution of land revenue.
    
8. Appellate Authority for Revenue Orders: An appeal can lie against an original order passed by any revenue officer to the next higher authority in the administrative hierarchy.
    
9. Hierarchy of Appeals:
   • Orders of Talathi/Patwari can be appealed to the Tehsildar/Revenue Inspector.
   • Orders of the Tehsildar can be appealed to the Sub-Divisional Officer (SDO)/Assistant Collector.
   • Orders of the SDO/Assistant Collector can be appealed to the District Collector.
   • Orders of the Collector can be appealed to the Divisional Commissioner.
   • In certain cases, further appeal can lie to the Board of Revenue or equivalent authority.
      
10. Appeal to Higher Judiciary: In case of dissatisfaction with the administrative appellate authority, parties may approach the High Court or Supreme Court, particularly if constitutional or legal questions are involved.
     
11. Powers of the Appellate Authority: The appellate authority has several powers to ensure justice and correctness in administrative decisions:
    • Review and Re-examination: Examine the legality, validity, and fairness of the original order. Ensure compliance with procedural requirements and applicable laws.
    • Hear arguments from both parties: Provide an opportunity for the affected party to present their case and challenge the original order.
    • Modification: Alter or modify the original order to correct errors.
    • Reversal: Quash the original order if found unjust or unlawful.
    • Remand: Send the case back to the original authority for reconsideration with specific directions.
    • Adjudication: Resolve disputes arising out of conflicting claims or interpretations of land revenue laws.
    • Stay Orders: Grant a stay on the execution of the original order pending final decision.

Conclusion
The complex web of land laws in India reflects the nation's commitment to balancing various stakeholder interests while ensuring efficient land administration and management. These laws have evolved significantly from traditional systems to modern frameworks, addressing contemporary challenges such as fair compensation for land acquisition, protection of marginalized communities, and sustainable land use.

While implementation challenges persist, the legal framework continues to adapt through amendments and new legislation, striving to meet the changing needs of society while maintaining the fundamental principles of justice, equity, and sustainable development in land administration.
 
Written By: Mr.Syed Mohd Osama Azam, Ll.B. Final-Year Student, Saifia Arts, Commerce & Law College, Bhopal (Mp)
Email: [email protected], Ph no: 7000657720