As per case facts, the appellant's lease for slate quarries in the Venkatagiri Estate was terminated by the Board of Revenue, which found the lease was granted after July 1, ... 1945, and for a period exceeding one year, without providing the three months' notice or compensation that the appellant contended was required. The appellant had also applied for renewal of the lease, which was rejected. Dissatisfied with these decisions, the appellant filed writ petitions challenging both the termination and the rejection of the renewal application. The question arose whether the termination of the appellant's leasehold rights, created after July 1, 1945, necessitated three months' notice and compensation under the third proviso and sub-section (2) of Section 20 of the Madras Estate (Abolition and Conversion into Ryotwari) Act, 1948, or if the second proviso rendered such rights void or voidable against the Government without these conditions. Finally, the Supreme Court held that the appellant's contention lacked merit. The Act's scheme was to render all rights created after July 1, 1945, and exceeding one year, ineffective. Section 20, properly construed, indicated that its second proviso was a self-contained provision making such rights void against the Government, and the aid of the third proviso was unnecessary for their termination. The third proviso was deemed to refer solely to the termination of rights created *before* July 1, 1945. Furthermore, the Court stated that the rule framed by the Madras Governor could not change the true meaning of Section 20, and rule 47 of the Mineral Concession Rules, 1949, could not apply when the lease itself was determined under the second proviso.