Indrani v. Pathirana and Others – sllr 2003 volume 1 page 356

In the case between Indrani (Plaintiff) and Pathirana and Others (Defendants), the court addressed the legality of inquiry proceedings conducted under the Agrarian Services Act in the context of non-payment of rent, issues arising from the substitution of the tenant cultivator upon death, and the manifestation of bias by the inquiry officer. It was held that the inquiry officer erred by focusing on the general character of the substituted tenant instead of determining the specific act of non-payment by the deceased tenant, failing to conduct the yield assessment mandated by section 17(5) of the Act, and misapplying legal provisions regarding the succession of tenancy. The decision reaffirmed that the rights of a substituted tenant cannot be terminated on the basis of defaults committed by