Agricultural Law: Evaluation on basis of the Constitution of India.


By Arindam Datta

B.A.LL.B., Department of Law, University of Calcutta.


            It’s an evident fact that the poor in India are still overwhelmingly concentrated in the rural areas, comprising about 570,000 villages. They are engaged mostly in agriculture or allied occupations, which form the principal source of livelihood of the rural population, accounting for nearly four-fifths of total rural employment

            About two-thirds of the country’s labour force consists of cultivators and agricultural labourers. As per the 32nd and the 48 the Rounds of the national Sample Survey (NSS), 51.2 and 40.4 per cent of the rural population were below poverty line 1977/78 and 1983/84, respectively.1 Rural poverty is concentrated largely in backward, drought-prone and flood-prone areas. Per capita income in the rural sector is still much lower than in the urban sector, and the absolute number of poor households in rural areas has increased over the past few decades. NSS data reveal a marked disparity in the distribution of land in the rural areas. Over 60 per cent of the land holdings in rural India as a whole consisted of small holdings below one hectare in area, the proportion being much larger in states like west Bengal and Kerala, where the man-land ratios are very high.2 According to the Agricultural Census (1980-81), 50.5 millions ( that is about 56.5 percent) of a total of 89.4 million holdings measured up to one hectare. About 16.1 million farms were between one and two hectares in size. Together, they made for 66.6 million farms or approximately 74.4 per cent of all the farms in India, but accounted for hardly 26 per cent of the cultivated acreage.3 These small and marginal4 rural household had a total of 373 million people.5 This, together with the other socio-economic group of agricultural labourers, represented the hard core of the rural poor and those who were on the lowest rung of the ladder.6

Rural development which begins with agricultural development, involves both economic and social transformation. It means improving the living standards and the quality of life of the rural poor, as well as making the process of their development self-sustaining. The growing rural-urban divide, reflected in disparities of per capita income and living standards, must be bridged in order to achieve the above.7 Unfortunately, even in the final decade of the twentieth century, the urban class controls the state which is the embodiment of powerful interests, especially the interests of the city. By and large it’s the urban interests and goals that determine the development policies, which are aimed at protecting and enhancing urban-based industrial and economic activities and services; village based industrialization and other aspects of rural development, like health and education have been relatively neglected. The urban bias was staunchly opposed by nationalist  stalwarts like Tagore and Mahatma Gandhi.8 In fact, four decades of planned development in India have mostly hinged on he development of large-scale industries and the urban sector, while the problems of poverty and unemployment which plagued the country at the time of independence remain rampant.9 There is no denying that without ensuring significant progress in the languishing agriculture-rural sector, not much success can be achieved in solving these problems.

Secondly, in agrarian economies, equity and efficiency considerations cannot be divorced from each other. Recent literature has considered the effect of existing or growing inequality in wealth distribution on technological change and productivity. Concerns has been expressed that the existing archaic structure of rural society and the growing interpersonal inequality within less developed countries (LDC) like India have impeded the adoption of certain innovations. Agricultural and rural development in India will be shaped essentially by how power is distributed among different social groups. Another problem is with respect to technology which is essentially a set of social and physical relationship or modes of interaction between men and the mechanisms with which he works,10 and therefore, it may be construed as a social and institutional phenomenon.11 Just as social and agrarian structures condition technology and economic development, the latter although many social and institutional changes are to some extent ‘autonomous’, they may also come about in response to technological change.12 Another important facet to poverty-eradication policies have often been associated with the increasing relative poverty, that is deterioration in the relative position of the rural poor vis-à-vis the rural rich. Poverty alleviation obviously does not imply merely bringing the poor above the poverty line namely, a reduction in absolute poverty. It also involves the reduction in inequality of income and assets which as stated earlier is desirable for both equity and growth. This would ensure the rural poor farmers derive greater bargaining power against wealthier groups and gain better opportunities to participate in the process of transformation.

The paper deals with whether there is a constitutional obligation upon the state to ensure that the mandate under Article 21 of Constitution of India is met in matters pertaining to Agricultural Law and if not then what could be the course of action against such erring states. In order to do so we have to evaluate Jurisprudential growth of Article 21 vis-à-vis Constitutional Rights of poor farmers in rural India. 

The Nature and Scope of Article 21—An Overview

Like in the constitutions of other democratic countries, the Constitution of India contains a catalogue of fundamental rights. These rights together form the boundaries of India’s legal framework: all other laws and regulations as well as all activities of the government at any level have to be in accordance with this framework. One such article is Article 21 which states—

“No person shall be deprived of his life or personal liberty except according to procedure established by law.” 

Article 21, though couched in negative language confers on every person the fundamental right to life and personal liberty.13 This right which is one of the most fundamental of all rights is also the most difficult to define. A reference with respect to its import can be seen from the corresponding provision in the 5th and 14th amendment of the U.S Constitution, which says that no person shall be deprived of his “life, liberty or property without due process of law”, in Munn v Illinois14, Field, J. spoke of the right to life in the following words:

“By the term ‘life’ as here used something more is meant than mere animal existence. The inhibition against its deprivation extends to all those limbs and faculties by which life is enjoyed. The provision equally prohibits the mutilation of the body by amputation of an arm or leg, or the putting out of an eye, or the destruction of any other organ of the body through which the soul communicates with outer world.” 

This statement, which has been repeatedly quoted with approval by our Supreme Court, has been further expanded in Francis Coralie v Union Territory of Delhi15 by the statement “that any act which damages or injures or interferes with the use of any limb or faculty of a person, either permanently or even temporarily, would be within the inhibition of Article 21”. In the same case Bhagwati, J. held:

“We think that the right to life includes the right to live with human dignity and all that goes along with it, namely, the bare necessaries of life such as adequate nutrition, clothing and shelter over the head and facilities for reading, writing and expressing oneself in diverse forms, freely moving about and mixing and commingle with fellow human beings.” 

The judge conceded that “the magnitude and content of the components of this right would depend upon the extent of the economic development of the country”, but emphasized that “it must, in any view of the matter, include the right to the basic necessities of life and also the right to carry on such functions and activities as constitute the bare minimum expression of the “human self”. In the recent years this article has taken an unprecedented activist role which includes  rights like right to healthy environment,16 right to livelihood17, a right to live with human dignity free from exploitation18, right to health19 etc. 

Rights available to poor farmers as the law stands now

            I.        The right to food (An Important Aspect of Food Security) is not just a basic human right but also a basic human need. It essentially requires the state to ensure at least that the people do not starve. States have to take all necessary steps towards fulfilling the right to adequate food. Under the Indian Constitution, there is no fundamental right to food but the fulcrum of justifiability of the right to food comes from a much broader "right to life and liberty" as enshrined in Article 21. In fact, the basis of the much talked about petition filed by the People's Union for Civil Liberties (PUCL) against the Union of India is Article 21. The petition drew attention to the fact that over 50 million tones of food grains were lying idle in FCI godowns against the backdrop of widespread hunger in the country, especially in the drought-affected areas of Rajasthan and Orissa. This led to an interim Supreme Court order directing the States to implement fully eight different centrally-sponsored schemes on food security and to introduce cooked midday meals in all Government and Government-assisted schools.

India does not seem to have any problem in terms of physical availability as the food grains production is more than adequate as evident from the overflowing godowns. Accessibility is the problem. This has two elements: physical accessibility and economic accessibility. There is a network of half-a-million fair price shops to make food grains physically available to Indian households. However, the public distribution system is grossly flawed. Field investigations by various NGOs in Jharkhand, Chhattisgarh, Madhya Pradesh, Orissa, Maharashtra and Rajasthan revealed that large numbers of cardholders are ignorant of their entitlements.

The principal constraint in realizing the right to adequate food is economic accessibility or affordability. This brings to the fore two main issues: (1) the price of the food grains and (2) the economic means to exercise `command' over the food. The relief or ad hoc employment provided to farmers during the lean season or to landless labourers and tribal for a short duration does not bring enough money — to feed themselves or their families adequately. Another important issue is the interface between the right to food and the right to health on the notion of `adequacy'. According to Asjborn Eide, U.N. Special Rapporteur on Right to Food, once foodstuffs are physically available, they have to satisfy the dietary needs (energy and nutrients) to qualify as adequate. The alarming nutritional status of poor farmers is primarily attributed to chronic hunger. To do away with this chronic under-nourishment, adequate food with all dietary elements is not enough. Adequate food must be accompanied by a provision for adequate health care. Under the Indian Constitution within the ambit of the aforementioned article right to health is also envisaged as an integral part of right to life.20

An assessment of the initiatives of the Centre and the State Governments to satisfy the right to adequate food and right to health after the Supreme Court's interim order makes it clear that the state has failed in various ways to protect, facilitate and provide adequate food. The food security schemes specified in the interim order are not functioning in many States. The starvation deaths in Orissa's Kashipur village bear testimony to a clear lack of political will and seriousness on the part of the States along with corrupt local governments and the bureaucracy. An important instrument in asserting the right to adequate food is legal action. Of late, the Supreme Court has started entertaining Public Interest Litigation highlighting questions of public importance. The PIL filed by the PUCL against the Union of India (SCC 196 of 2001) is one such celebrated petition on the violation of the right to food. However, such legal action does not touch upon all aspects of the right to food. The role of civil society is of paramount importance. Article 10 (Part IV) of the International Code of Conduct on the right to adequate food mentions that the active participation of all civil society actors — individuals, families, local communities or non-governmental organizations — is essential. Recently, social mobilization has begun in the form of public hearings. Public pressure through public hearing is effective in asserting the right to food. However, what is really needed is the participation of civil society in planning, executing, monitoring and evaluating public policies relevant to the right to adequate food. Only a participatory approach will be able to give a more humane shape and the much needed rights perspective to the Government's policies in ensuring food and nutrition security.

         II.        Another important issue cropping up recently is the right to education (An important part of Rural Development) debate. In Unni Krishnan v State of A.P21. The court has recognized a fundamental right to education in the right to life under Article 21. Taking help from Article 41 and 45 it has held the ‘every child/citizen of this country has right to free education until he completes the age of fourteen years’. Taking a que from this there is a concomitant right of the farmers to be taught the basics with respect to interest calculation, basic arithmetic etc so that it helps them understand the debt market which is the main cause for farmers harassment. Further under the instant provision they have a right to be taught the use of various products and the effects of the use of the same as it deals with their health as well as the well being of the society at large.

       III.        Another aspect to the above right is Enjoyment of life (…) including [the right to live] with human dignity encompasses within its ambit, the protection and preservation of environment,(An Important Aspect of Agriculture Development) ecological balance free from pollution of air and water, sanitation, without which life cannot be enjoyed. Any contra acts or actions would cause environmental pollution. Environmental, ecological, air, water pollution, etc. should be regarded as amounting to violation of Article 21. Therefore, hygienic environment is an integral facet of right to a healthy life and it would be impossible to live with human dignity without a human and healthy environment”. Form this facet emanates gamut of rights which include right to clean water for agriculture. A typical situation has arisen where the farmers in most places are forced to use sewage water and the untreated water from the factories. Even the ground water is polluted and unsafe for use. The above is causing serious ailment amongst farmers as well as jeopardizing the success of crops. Therefore this right is a new addition to the farmer’s basic right to live with human dignity.

      IV.        One of the most powerful additions to the nature of right envisaged under Article 21 is the right to livelihood. Initially, for some time the Court held the view that right to life in Article 21 does not include right to livelihood.22 After some controversy on that issue23 the Court has clearly held that right to livelihood is included in the right to life “because no person can live without the means of living, that is, the means of livelihood”. In the celebrated decision of Olga Tellis v Bombay Municipal Corporation24 where the issue was with respect to eviction of slum-dwellers in the municipal area of Bombay. The court categorically held that eviction would cause a loss of livelihood which is a basic fundamental right under Article 21 of the Constitution.25 A final verdict was served in Dalmia Cement (Bharat) Ltd. v Union of India26 where it was held that Right of agriculturists to cultivation is part of their fundamental right to livelihood.27 Finally, one land mark case which is often regarded as the mother of PIL and which was directed against human exploitation was Bandhua Mukti Morcha v Union of India28. In this case the Court stated—

“It is the fundamental right of everyone in this country… to live with human dignity, free from exploitation. The right to live with human dignity enshrined in Article 21 derives its life breath from the Directive Principles of State Policy and particularly clauses (e) and (f) of Article 39 and Article 41 and 42 and at least, therefore, it must include protection of the health and strength of the workers men and women, and of the tender age of children against abuse, opportunities and facilities for children to develop in a healthy manner and in conditions of freedom and dignity, educational facilities, just and humane conditions of work and maternity relief. These are minimum requirements which must exist in order to enable a person to live with human dignity and no State… has the right to take any action which will deprive a person of the enjoyment of this basic essentials.29 

The above quote signifies an individual’s right against exploitation. Thus any farmer who is being exploited because of his inability to pay back the loan or for any other reason shall have an action against the State to ensure that his basic fundamental right to live with human dignity which includes a life free from exploitation is preserved.  

Moreover, there should be due recognition of the fact that all pivotal rights such as the right to food, right to health, right to education or any economic and social rights, for that matter, are interdependent and have important bearing in the life of poor farmers. For example, providing sufficient food to do away with under-nutrition will not really eliminate the chronic health disorders that have already set in. Providing adequate health care is necessary which gives way to a natural corollary that every individual must have a clean and healthy environment. Similarly, to realize the right to food or health people should have access to education and information. Finally, the above rights would be meaningless if the person does not have life free from exploitation. Therefore it can be concluded that each right is complementary and supplementary to other rights. For a successful enjoyment of the right under Article 21 it’s essential  the essence of Article 21 is protect which is a confluence to all such rights already talked about.

In order to evaluate the root of the problems, evaluation of deficiency in Rural Development Programme must be done.

Genesis of the Problem of Rural Development

There are three aspects of Rural Development; first relates to the tenancy reforms and abolition of intermediaries through which changes in the system of land-holdings were brought; the second relates to the ceiling on the land-holdings, consolidation of holdings, cooperative farming and distribution of land for cultivation to the new tellers on the land; and the third relates to the removal of elements of exploitation and social injustice in the agrarian system so as to create conditions for the social justice to agriculture labour. Land to tiller is a cardinal feature of the land policy. Land reforms have attempted to abolish forced labour through the Constitutional Mandate.30

      Though a pioneering work has been done with respect to land distribution there is serious lacunae in agricultural labour reforms and rural credit system. Agriculture credit is manifested as a key instrument of economic policy in most market-oriented developing countries. Credit is used as a catalyst and stimulant for the speedy development of a nation in general and agriculture in particular. Unfortunately, results of conventional agricultural credit programme have seldom measured up to expectations. Their effects have generally been overestimated by evaluation that ignores the way rural financial markets work. A rural financial market (RFM) consists of relationships between buyers and sellers of financial assets who are active in rural economics. These relationships are based on transactions that include borrowing, lending and transfers of ownership assets. Financial assets consist of debt claims and ownership claims. Debt claims are promises to pay. Example include verbal promises or scraps of paper signed by a thumb-point, as well as more formal evidence of indebtedness by individuals and deposit accounts that are debt claims on banks. RFMs include informal sector intermediaries, formal institutions and private borrowing and lending not involving intermediaries.31

      The All India Rural Credit Survey 1951 and All India Debt and Investment Surveys and the CRAFICARD 1981 have been the pioneering studies undertaken by the Reserve Bank of India (RBI). The All India Rural Credit Survey (AIRCS) was the most comprehensive, scientific undertaking. The findings of the Committee confirmed the dominant position occupied by the moneylender in the Rural Credit Market. It observed that agricultural credit fell short of the right quantity, was not of the right type, did not serve the right purpose and often failed to go to the right people.

      The other problem is with respect to agriculture labour which does not find place in the Land Reforms made during the last 50 years of independence. All the major land reforms made in various States related to the abolition of intermediary system, consolidation of holdings, settlement operations, conferment of tenancy rights and sub-tenants and fixation of ceiling on the holdings. Tenant was the pivot of all these land reforms. Unfortunately, the agricultural labour, who had played an important role in the agricultural production process, still occupies the lowest rung in the socio-economic ladder of the rural population. Our Constitution envisages that justice, social, and economic should be given to all the persons. Agricultural labour occupies the lowest place in the socio-economic structure of the land set up. Mostly, these problems belong to the scheduled castes and scheduled tribes or backward classes. They have no resource base and are mostly landless. During the last 50 years of independence there has been a tremendous rise in the total number of agricultural laborers in India.

The Apathy of the Farmers – An Interface with Reality:-As already stated rural population in India is mainly dependant on agriculture as the only source of their livelihood, the agricultural production is mainly, affected by the size of the agricultural holdings. The big land-holdings remained concentrated in the hands of a few persons whereas the vast rural population possesses either the small or marginal holdings or they were landless. For example in most parts of Rajasthan are one crop areas and in absence of any other crop in a year the cultivators and the agricultural laborers who could not obtain gainful employment incurred heavy debts for making their both ends meet. Since they could not repay the debts with interest in time they remained in debt throughout their lives and on their death the burden passes on their children.32 In Rajasthan each year has not remained normal. After every three years there was a famine or draught leading to crop failure and cattle mortality and tenants had no option but to borrow for their family necessities. The All India Rural Credit Survey Report said that proportion of indebted families raised between 31 to 85 according to earlier enquiries and between 55 and 79 according to rural credit survey in different States.33 The second agricultural Labour Enquiry, 1956-57, while enquiring about various aspects of agricultural labourers also collected data about the expenditure extent of indebtedness from 7861 agricultural labour households. It was found that of the estimated total number of 16.3 million agricultural labour households in the country, 63.9 percent were indebted and the debt per indebted household was Rs. 138 per annum. Thus the total average of such debt of the indebted agricultural labour households was estimated to be about Rs.143 crores in 1956-57. Another notable example is that of Andhra Pradesh. There are 11 million farmers in the Andhra Pradesh 90% of them are small farmers The state has been facing a drought since 2001. 70% of the state's 78 million people are dependent on agriculture. The agriculture is in a bad state. According to economist V. Hanumantha Rao says that lack of irrigation facilities and institutional loans to farmers and their overdependence on money lenders has led to the sorry state of affairs. Mostly, loans are given at a whopping 36% interest rate.34 The above reasons have lead to farmers suicide. Changal Reddy, president of Federation of Andhra Pradesh Farmers Associations, says the number of suicides always rise from April to June. He says there is a "deadly cocktail" of factors at play during these months that drives farmers to despair. For one, he says, the farmers come to know around this time whether their crop has failed. The state has been reeling under drought and crop failure has become common. Then, the money lenders swing into action to demand their money back. A total of 250 farmers committed suicide in Andhra Pradesh between 1995 and 1998, according to the government. There are no definitive records available after 1998 but the previous government stopped paying compensation to affected families on the ground that it was encouraging more farmers to commit suicide. The new chief minister Mr YS Rajashekhar Reddy stated that nearly 3,000 farmers in the state have committed suicide over the past six years.

Analysts state the spate of suicides is rooted in the endemic neglect of the farming sector in the state. Thus its evident that there is a general ignorance on the part of the State’s towards agricultural sector. This calls for another debate, whether there is a constitutional mandate upon the State to ensure that rights of poor farmer’s are protected so that they do not commit suicide. Right to life envisaged under Article 21 as already mentioned in the previous chapter is an integral part of the Constitution. All other rights can be successfully enjoyed if the instant right can be meaningfully exercised. As already discussed the ambit of this right has been tremendously increased and right to life includes life with human dignity. In light of this background it is understandable that ‘preservation of life’ is the most important facet of this article, cause all other expanded notions of rights envisaged under this article becomes meaningless in the absence of ‘life’ itself. Moreover, though Article 21 is negatively worded but it’s a settled principle of law that there is also a positive element to it. Thus the State not only has to ensure that ‘no person is deprived of his life with human dignity’ but also has to ensure through an affirmative action that every subject is enjoying a life with human dignity. Therefore, from the above two premises it can be safely concluded that there is a constitutional mandate (emanating from Article 21) upon the States to ensure preservation of meaningful life of it’s subjects. A concomitant argument that arises from the above discussion is what shall be the consequence if the aforementioned mandate is violated or not fulfilled by the State. An analogy can be drawn from the celebrated case of S.R. Bommai v Union of India35. Appeals from the judgments of the Gauhati, Karnataka and Madhya Pradesh High Courts and the writ petitions filed by Rajasthan and Himachal Pradesh High Courts, which were transferred to the Supreme Court, were heard by a nine-judge bench. The case was with respect to the interpretation of Article 35636 and the proclamation of emergency there under.  The most hotly debated issue before the Supreme Court was the validity of the Presidential proclamation and the dismissal of BJP governments in the States of Madhya Pradesh, Himachal Pradesh and Rajasthan.  The court unanimously upheld the action albeit by different process of reasoning. Secularism was considered to be a part of the basic structure and all the judges agreed upon the far reaching proposition that violation of a basic feature of the Constitution, including the secular features of the Constitution, is a valid ground for exercise of power under Article 356.37 They were interpreting the expression ‘the situation has arisen in which the government of the State cannot be carried on in accordance with the provisions of the Constitution’ under Article 356. One criticism leveled is that the basic structure theory evolved by the Supreme Court specifically with reference to the amending power cannot be invoked for exercise of power under Article 356 particularly when, according to the Supreme Court, the validity of parliamentary legislation cannot be tested on the basic structure theory. This criticism is invalid as the academics argue that the non-compliance with important part of the Constitution is undoubtedly a ground for imposing President’s rule. There is no reason in principle why Article 356 cannot be invoked when there is cogent and credible material that the government of a State is being carried on in violation of or defiance of the essential features of the Constitution.38  Thus its evident from the instant case that Article 356 gives power to the President to proclaim emergency if the State is not being carried on in accordance with the constitution. Its further evident that the expression ‘cannot be carried in accordance with the provisions of the constitution’ include State’s mandate to respect and uphold essential features of the Constitution. Therefore, taking a direct analogy from the above decision if the State does not ‘preserve life’ as envisaged under Article 21 which is the most essential feature of the Constitution (cause all other rights can be exercised only if ‘life is preserved’) then the State can be dismissed under Article 356 as it would violate the essential feature of the Constitution. This logic is also a foregone conclusion because ‘Secularism’ by any stretch of imagination is far lesser value than ‘preservation of life’ itself. If a nine judge bench stated that the former should be protected by the State then it can be conveniently concluded that the latter which is a far greater obligation should also be protected and in the absence of the same it would call for the proclamation of emergency under Article 356. 
 The test of the success or failure of the Constitution is its ability to fulfill what it promises: justice, social, economic and political; liberty of thought, expression, belief, faith and worship; equality of status and opportunity and fraternity assuring the dignity of the individual. In creating the three organs of government—the legislature, the executive and the judiciary—the Constitution assigned a specific role to each, but the assumption was that each would strive towards the common goal set out in the Preamble. Among the three organs judiciary was bestowed upon the pristine task to ensure compliance of these organs with the provisions of paramount law of the land. It is settled that it is for the Legislature to frame the right laws and it is for the Executive both to formulate and execute policies, but the Constitution has made the judiciary the sole interpreter of the Constitution, and, to that extent, it sets the tone. There appears to be a general agreement that in recent years the Supreme Court has brought about more for-reaching changes than legislature and executive combined. Except in America in no other democracy does the judicial branch of government occupy a prominent position comparable to that of which it has assumed in Indian system. Like the American Supreme Court, the Indian Supreme Court too in the recent past has expanded its role by transcending the traditional notion of separation of powers and has created altogether new kind of prison jurisprudence39, has created altogether new kind of rights in the citizens40 and new kinds of remedies against the governmental lawlessness41. However, a lacunae has been seen in the judicial endeavor with respect to the rights of poor farmers who form a sizeable portion of the Indian polity. Judiciary has done a commendable job in bringing individual’s right to food and livelihood within the purview of Article 21 but no specific right has been envisaged with respect to poor farmers. Thus there should be an attempt on the part of the judiciary to increase the ambit of ‘judicial activism’ in broadening the scope of Article 21 to incorporate specific rights in favour of the farmers. Since its already discussed that there is a positive duty upon the State to ensure that the right guaranteed under the instant article is protected, an expanded notion of the right would ensure better protection. The solution to the problems of rural agriculture is wide ranging and it lies in the concerted effort of the institutional and structural changes that are specially designed to compensate for economic, social and political weakness of the underprivileged sections. The structural solutions to the problem are concentration on other facets of agricultural reforms apart from land reforms viz agricultural labour reforms and rural credit system. Crop insurance and monitoring of the unorganized debt system which usually lead to exploitation should be a State mandate. This should be brought under the expression “a life with human dignity” envisaged under Article 21 of the constitution.. And as already mentioned if the constitutional mandate is not adhered to by any state it shall call for the exercise of power under Article 356 of the constitution. 



Primary Document 

List of Cases 

1.  Bandhua Mukti Morcha v Union of India (1984) 3 SCC 161

2.  Begulla Bapi Raju v State of A.P. (1984) 1 SCC 66

3.  Dalmia Cement (Bharat) Ltd. v Union of India (1996) 10 SCC 104

4.  Delhi Transport Corporation v D.T.C.Mazdoor Congress 1999 Supp (1) SCC 600, Delhi

5.  Development, Horticulture Employee’s Union v Delhi Administration (1992) 4 SCC 99

6.  Francis Coralie v Union Territory of Delhi (1981) 1 SCC 608

7.  Munn v Illinois  94 U.S. 113

8.  Nagendra Kumar v State of Haryana (1994) 2 SC 94

9.  Olga Tellis v Bombay Municipal Corporation  (1985) 3 SCC 545

10.  State of Punjab v Mahinder Singh Chawla  AIR 1997 SC 1225

11.  Unni Krishnan v State of A.P  (1993) 1 SCC 645

12.  Vellore Citizens Welfare Forum v Union of India  AIR 1996 SC 1715

13.  Vikaram Deo Singh Tomar v State of Bihar 1998 Supp SCC 734


Secondary Document 


B.N.Yugandhar and P.S.Datta, Land Reforms in India Rajasthan Feudalism and Change, Sage Publications, New Delhi, 1995

C.V.Joshi, Agrarian Structures & Tenancy Movements, Rawat Publications, New Delhi, 1999

G.S.Bhalla and Gurmail Singh, Indian Agriculture Four Decades of Development, Sage Publications, New Delhi, 2001

H.C.L Merillat, Land and Constitution in India, N.M.Tripathi Pvt Ltd, Bombay, 1970

Heni Streefkerk and T.K.Moulik, Managing Rural Development, Sage Publications, New Delhi, 1991

Peter.P.Mallinga, Water for Food and Rural Development, Sage Publications, New Delhi, 2000

S.R.Bhansali, Land Reforms and Agricultural Labour in India, Ina Shree Publishers, Jaipur, 1998

Sandeep Joshi, IRDP and Poverty Alleviation, Rawat Publications, New Delhi, 1999

Seervai H.M., Constitutional Law of India, Universal Book Traders, 4th ed., New Delhi, 1997

Shukla V.N., Constitution of India, Eastern Book Company, 10th ed., Lucknow, 2003

Usha Jha, Land, Labour and Power, Aakar Book, Delhi, 2003

Vandana Shiva and Gitanjali Bedi, Sustainable Agriculture and Food Security The Impact of Globalisation, Sage Publications, New Delhi, 2002