Adikaram v. Ratnawathie Bandara and Another – sllr 1990 volume 1 page 129

The case between Adikaram (Plaintiff/Appellant) and Ratnawathie Bandara and Another (Defendant/Respondents) concerned the interpretation of “owner cultivator” under the Agricultural Lands Law, No. 42 of 1973. The primary issue was whether permit holders under the Land Development Ordinance must physically cultivate the land to qualify as owner cultivators, and the prospective versus retrospective effect of statutory provisions on acquired rights. It was held that the new law deems permit holders to be owner cultivators regardless of actual cultivation, thereby overriding claims based on past ande (sharecropping) cultivation. The principle reaffirmed is that statutory fictions must be given full effect, and the rights acquired earlier are protected unless explicit retrospective application