another person, even though the sale will not be valid, the permit holder or the grant holder will not be entitled to claim the land as he had disposed it in violation of the condition. Large extents of lands given on grants or annual permits are today not always held by the grantees or the permit holders or their successors. The original permit holders have been displaced and their properties are occupied and developed by unauthorised occupants. In some cases, the original holder of a permit or a grant has transferred the land to another person without the permission of the Government Agent. The situation would be different if the permit holder had given the land on lease or authorised another person to occupy the land due to his inability to remain in the area. When the grant holder returns to his land and finds a trespasser in possession, the only remedy available to him is a vindicatory action against the trespasser. Similarly, a permit holder under the LDO also enjoys sufficient title to enable him to maintain a vindicatory action against a trespasser. As this is a regular District Court action, it will take a considerable period of time to resolve. Under the provisions of Chapter XII of the LDO, the Government Agent can also institute action to eject an unauthorised person who has encroached onto permit land. The Government Agent considers cases where the land of a displaced person is occupied by an unauthorised person, a licensee or a bona fide purchaser from a third person who refuses to vacate the land. If the licensee, unauthorised person or a bona fide purchaser has developed the land or is a person falling under the category of persons entitled to receive state lands, we recommend that the Government agent, after regularising the occupation, may offer alternate state land to the original grant holder or permit holder. In the event that the permit holder has been displaced and, by virtue of non-occupation of the land, lack of development of the land and/or failure to meet land tax payments, is in breach of the conditions attaching to the permit, the State may, after holding an inquiry, cancel the permit (ss106-110 of the LDO). The spouse or the nominated successor of a deceased person may lose the land, which was given on permit by failure to succeed as provided by the LDO. The LDO also provides that if the spouse, or the nominated successor, of a deceased permit holder does not succeed by obtaining a permit from the Government Agent under the provisions of the LDO to occupy that land, or failed to enter into possession within a period of six months reckoned from the date of the death of the permit holder or owner, he shall deem to have surrendered his title to that land to the state. The succession provided in the LDO authorises the permit holder to nominate a person of his choice - it may be his wife, a child or any other relative by blood (LDO Rule 1). This arrangement is provided to monitor the actual development of the land and the landless persons to enjoy the benefit of the land. If the land is allowed to devolve in the normal course of succession, the land may be divided among all children and the spouse and, as a result, be fragmented, which would not serve the purpose of the LDO. Therefore succession provided in the LDO cannot be termed as discriminatory. The Supreme Court has held that the surrender of land held on permit under the Land Development Ordinance does not mean the same thing as cancellation of the permit. Where a land has been surrendered to the crown by a permit holder, the Government Agent is not entitled to invoke the powers of the Magistrate’s Court (under section 125 of the Land Development Ordinance) for the purpose of obtaining an order of ejectment of any person who is in possession of the land. In such a case the Crown must seek ordinary remedy. The existing legislation or the common law does not adequately address these issues and claims of displaced persons who return to the property obtained under a Crown grant/ permit, which is now occupied by another. In our view, instead of bringing legislative 26