Karuppaia Rengaraj vs J M C Priyadharshani – CA PHC/67/2011-2017

In the case between Karuppaia Rengaraj (Appellant) and J M C Priyadharshani (Ministry of Plantation Industries) (Respondent), the court addressed whether the appellant had lawful authority, through a valid permit or written authority, to occupy or possess State land under the State Lands (Recovery of Possession) Act. It was held that mere occupation without a valid permit or authority is insufficient to withstand eviction, reaffirming the principle that the burden rests on the occupant to prove lawful possession in proceedings under the Act. This decision relied on Section 9 of the State Lands (Recovery of Possession) Act and relevant precedent, notably Muhandiram v Chairman, Janatha Estate Development Board, emphasizing that prior proceedings do not operate as res judicata unless there is