In one set of cases it was ruled that the burden of proving that a tenant is entitled to permanent rights of occupancy in his holding by virtue of section 6 of the Madras Estates Land Act always lies upon the tenant, and it is for the (1) I. 857 tenant to establish affirmatively that the minor inams in the village were granted before the date of the grant of the named village, and if he failed to do so his claim is liable to fail : see Rama Rao vs Linga Reddi(1) and Ramadhan Chettiar vs State of Madras(2) In another set of cases it was held that where relief is claimed before the Court on the plea that a grant of land was of an estate, or that it was not of an estate, and the evidence is inconclusive, the person who has approached the Court for relief must fail : see the judgment of Krishna Rao J., in Nelluru Sundararama Reddy vs State of Andhra Pradesh (3) ; Varada Bhavanarayana Rao vs State of Andhra Pradesh ( 4 ) ; and Addanki Thiruvenkata Thata Desikacharyulu Ayyavarlamgaru vs The State of Andhra Pradesh and Ors.(5) In the third set of cases it was held that the Explanation raises a presumption where a grant is expressed to be of a named village, that the area which formed the subjectmatter of the grant shall be deemed to be an estate, and it is for the party contending that the grant in question falls outside the definition of section 3 (2) (d) of the Act to prove that case either by showing that the minor inams not comprised in the grant were created contemporaneously with or subsequent to the grant of the village by the original grantor : see Janakiramaraju vs Appalaswami(6); Nelluru Sundarama Reddy vs State of Andhra Pradesh (7) State of Andhra Pradesh vs Korukonda Bhattam Appalacharyulu(8) and Sri Varadarajaswamivari Temple vs Sri Krishnappa Govinda and others(9).