Indian Oil Corporation Ltd. v. P.C. Sathiyadevan (D) - S.106 Kerala Land Reforms Act - Commercial Lease
Supreme Court On Conditions To Be Fulfilled By Lessee In Order To Have The Benefit Section 106 Kerala Land Reforms Act
Kerala Land Reforms Act 1963- Section 106- There are primarily two conditions to be fulfilled by a lessee in order to have the benefit of this section: Firstly, the lease must be for commercial or industrial purposes; and secondly, the lessee must have constructed buildings for such commercial or industrial purpose before 20.05.1967 which is the appointed date. 4.1 If both the conditions are fulfilled; such a lessee shall not liable to be evicted from such land but shall be liable to pay rent under the contract of tenancy and such rent shall be liable to be varied every twelve years. (Para 3-4) [Context: The Supreme Court dismissed Indian Oil Corporation’s appeal and upheld the Kerala High Court’s decision directing it to hand over possession of the leased land, as IOC failed to prove that the petrol pump structures were constructed before 20.05.1967 to claim protection under Section 106 of the Kerala Land Reforms Act. ]
Case Info
Case name: Indian Oil Corporation Ltd. v. P.C. Sathiyadevan (D) by LRs. and Another
Case number: Civil Appeal No(s). 8576/2011
Judges’ names:
- Hon’ble Mrs. Justice B.V. Nagarathna
- Hon’ble Mr. Justice Alok Aradhe
Date of order/judgment: 21 January 2026
Laws cited:
- Section 106 of the Kerala Land Reforms Act, 1963 (special provisions relating to leases for commercial or industrial purposes)