Rajagopalan, O.C.J. — In anticipation of the abolition of the zamindari estates and other estates as defined by Madras Act I of 1908 the Madras Legislature enacted the Madras Estates Land (Reduction of Rent) Act, 1947 (XXX of 1947) to relieve immediately the tenants in the estates of the burden of what were considered to be the excessive rents they were then paying the landlords. Subsequently the Madras Estates (Abolition and Conversion into Ryotwari) Act, 1948 (XXVI of 1948) provided for the abolition of the estates themselves and for bringing those areas under the ryotwari system. A number of religious, educational and charitable institutions, to which we shall hereafter refer comprehensively as institutions or religious institutions, owned such estates, which had been granted in inam for the upkeep and maintenance of these institutions. Special provisions were made in both the Acts to maintain what was considered by the Legislature to be a just balance between the interests of such public institutions and those of the tenants in the estates they owned. While the interests of the tenants were safeguarded on the same lines as those of the tenants in other types of estates, a more

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