JUDGMENT : ZIYAD RAHMAN A.A., J. This review petition is submitted by the Government, seeking review of the judgment passed by this Court. The facts that led to the filing of this review petition are as follows: 2. The writ petitioner, who was the owner of a property described as paddy land in the revenue records, obtained Ext.P2 order dated 13.08.2012, under Section 9 of the Kerala Conservation of Paddy Land and Wetland Act, 2008 (hereinafter referred to as “Paddy Land Act), by filing an application in Form-I, that enables the owner of a paddy land, to construct a residential building on his property described as paddy land. Based on the same, the writ petitioner converted the property and carried out the construction of the building. Thereafter, when Sections 27A to 27C were introduced in the Paddy Land Act with effect from 30.12.2017, the writ petitioner submitted an application in Form-A, for reassessment of the property as contemplated under Section 27C of the Act. Since there arose a confusion with regard to the proper authority to consider the said application, i.e. whether it is the Tahsildar (Land Records) or Tahsildar of the Taluk concerned, the petitioner approached this Court by filing the writ petition. 3. The writ petition was disposed of holding that, the proper authority to consider an application under subsection (2) of Section 27C, is the Tahsildar (Land Records) and therefore, a direction was issued to the said Tahsildar, who was the 3 rd respondent in the writ petition, to consider the said application and pass appropriate orders. In implementation of the directions in the judgment, the property was reassessed, but in the tax receipt, the description of the property was shown as “Nilam”. Therefore, a Contempt of Court Case was submitted by the petitioner as Con.Case(C) No.1170/2025 alleging non-compliance of the directions issued by this Court. 4. According to the review petitioners, it was at this juncture, it was noticed that the writ petitioner is a person, who purchased the property from the original land owner, after the enactment of the Paddy Land Act and therefore, he is not entitled to the benefit of Section 9 of the Act. 4. According to the review petitioners, it was at this juncture, it was noticed that the writ petitioner is a person, who purchased the property from the original land owner, after the enactment of the Paddy Land Act and therefore, he is not entitled to the benefit of Section 9 of the Act. It was also contented that, application under Section 27C(2) cannot be entertained by the Tahasildar, for the purpose of reassessment and no change of category to “Purayidom” can be effected by the said Tahsildar, as the permission granted to the petitioner, was only to reclaim the land under Section 9 of the Act for residential purpose and not to change the nature of the land. This review petition is sought in such circumstances. 4.1 I have heard Smt.Nimmy Johnson, the learned Government Pleader for the review petitioners and Sri.K.C.Vincent, the learned Counsel for the respondent/writ petitioner. 5. The main contention raised by the learned Government Pleader is that, going by the statutory stipulations contained in Section 27C(2) of the Act, the reassessment of property can be made, only in respect of the applications, by which, the conversion was permitted under Section 27A of the Paddy Land Act and the same cannot be made applicable to a permission for reclamation as contemplated under Section 9 of the Act. 6. Before examining the said contention, it is profitable to refer to section 27C of the Paddy Land Act, which provides for the change in records, consequent to the conversion of the property and section 27C reads as follows: “Section 27C . Changes in records -(1) Notwithstanding anything contained in any other law for the time being in force or in any judgment, decree or order of any Court, Tribunal or any other Authority, whenever a part of a survey number of subdivision is permitted to be converted under Sections 8, 9, 10 or 27A of this Act, a new subdivision shall be created for the extent for which such orders for conversion are issued. (2) Where the paddy land or unnotified land is duly converted as per the provisions of this Act, the Tahsildar shall reassess the land tax under section 6A of the Kerala Land Tax Act, 1961 (3 of 1961) and make necessary entries in revenue record relating to such lands. (2) Where the paddy land or unnotified land is duly converted as per the provisions of this Act, the Tahsildar shall reassess the land tax under section 6A of the Kerala Land Tax Act, 1961 (3 of 1961) and make necessary entries in revenue record relating to such lands. (3) Where such changes are recorded in revenue record, the number and date of the order and the authority granting sanction, the survey number of the lands for which sanction has been accorded , extent of the land in each survey number for which sanction has been accorded and revised land tax shall be clearly recorded ensuring that the old entries are legible. (4) Tahsildar shall conduct periodontal inspection to ensure that changes in revenue records are in accordance with sub-section (3). (5) No attempt shall be made to alter or change or modify the revenue records relating to the paddy land or wetland or unnotified land otherwise than in accordance with sub-section (3).” 7. After carefully going through the statutory stipulations contained in the said provision, I do not find any justifiable reason to accept the contention raised by the learned Government Pleader. This is particularly because, going by Section 27C, it can be seen that, subsection (1) of said provision deals with the procedure for creating a new subdivision in respect of the paddy land when a part of a survey number or subdivision is permitted to be converted under Section 8, 9, 10 or 27A of this Act. Thus, the creation of new subdivision is contemplated in cases where, the property is converted under section 9 also, which is a conversion for residential purposes, for the owner of a paddy land. In this case, conversion was ordered/permitted under Section 9. According to the learned Government Pleader, sub-section (2) of Section 27C, is a distinct provision, which has nothing to do with the subsection (1). It was pointed out that, sub-section (2) provides that, where the paddy land or unnotified land is duly converted as per the provisions of this Act, the Tahsildar shall reassess the land tax under Section 6A of the Kerala Land Tax Act, 1961 and make necessary entries in the revenue records relating to such lands. It was pointed out that, sub-section (2) provides that, where the paddy land or unnotified land is duly converted as per the provisions of this Act, the Tahsildar shall reassess the land tax under Section 6A of the Kerala Land Tax Act, 1961 and make necessary entries in the revenue records relating to such lands. Thus, according to the learned Government Pleader, what is directed in the judgment, is to follow the procedure contemplated under Subsection (2) of Section 27C, which is not applicable in respect of a property reclaimed under Section 9 and hence, a modification of the judgment is required, to that extent. 8. However, the crucial aspect to be noticed in this regard is that, as far as the scope of the proceedings contemplated under sub-section (2) of Section 27C is concerned, it is to be noted that, the said provision does not refer to any specific statutory provision under the Paddy Land Act; neither Section 9 nor Section 27A. Instead of that, the said provision deals with the ‘paddy land” as well as ‘unnotified land’, which are “duly converted as per the provisions of this Act” . 9. I f the intention of the legislature was to confine the benefit of subsection (2) of Section 27C, only to the properties converted under Sec.27A, the expression ‘paddy land’ in addition to the ‘unnotified land’, should not have been incorporated in the provision. The very fact that, in addition to “unnotified land”, (which alone is dealt with in section 27A), “paddy land” is also specifically referred to in the said provision itself indicate that, scope of the same is not confined to the land covered under Sec.27A alone. The legislature apparently does not intent to bring a distinction between ‘paddy land and ‘unnotified land’ , as observed rightly in The Tahsildar & Anr v. Renjith George CIVIL APPEAL No.14732 OF 2024, where, the following observations were made, although in a slightly different context: “11. The short question that ultimately fell for consideration before the High Court was as to whether the conditions embedded through the 2018 Amendment Act shall apply on pending applications for change of the nature of `paddy land’ to `non-agricultural purposes’. The short question that ultimately fell for consideration before the High Court was as to whether the conditions embedded through the 2018 Amendment Act shall apply on pending applications for change of the nature of `paddy land’ to `non-agricultural purposes’. We may hasten to add here that despite the insertion of a separate definition of `un-notified land’, the legislature has treated both `paddy land’ and `unnotified land’ at par for the purpose of their conversion as non-agricultural lands. The nature of land, whether a `paddy land’ or `un-notified land’ thus becomes immaterial when applying its conversion to non-agricultural purposes. The only issue that survives is whether the conditions introduced through the 2018 Amendment Act can be applied to the applications which were already pending consideration before the amended Act came into force”. Therefore, the contention of the learned Government Pleader in this regard cannot be accepted. 10. Apart from the above, another contention raised by the learned Government Pleader is that, the word used in subsection (2) of Section 27C is “duly converted” whereas, what is permitted under Sec.9 is “reclamation”. Of course, it is true that, in Sec.9(1), while dealing with the application for construction of residential building on a paddy land, what is referred to is “reclamation of paddy land” and not conversion of paddy land. However, going through the definition of expression 'reclamation' as contained in 2(xv) of the Act, it can be seen that, “reclamation” includes conversion as well. The said provision reads as follows:- (xv) “reclamation” means such act or series of acts whereby a paddy land or a wetland as defined in this Act is converted irreversibly and in such a manner that it cannot be reverted back to the original condition by ordinary means; The expression “conversion” is defined under section 2(iii), which reads as follows; (iii) “conversion” means the situation whereby, land that has been under paddy farming and its allied constructions like drainage channels, ponds, canals, bunds and ridges are put to use for any other purpose; 11. Thus, it can be seen that, “reclamation” is intended to mean the change in the nature of paddy land or wetland by way of irreversible conversion. The term “conversion” is defined in the Act, as an act of putting a property to use for any other purpose. Thus, it can be seen that, “reclamation” is intended to mean the change in the nature of paddy land or wetland by way of irreversible conversion. The term “conversion” is defined in the Act, as an act of putting a property to use for any other purpose. Thus, very wide definitions are given to the terms “reclamation” and “conversion” , and such wideness, is not restricted by any of the other provisions in the Act, expressly or with necessary implication. Moreover, in Sec.27C(1) itself, the word used is “converted” and not “reclamation”. Even though the said provision specifically refers to the procedure for change in records, such procedure is made applicable to the “conversion” under Sec.9 of the Act also. Therefore, it is evident that, the statute itself uses words “conversion” and “reclamation” interchangeably, and hence, the fact that, subsection (2) of Section 27C does not contemplate the expression “reclamation”, does not have significance at all, when it comes to the applicability of the said provision to a property reclaimed under Section 9. 12. Therefore, the only conclusion possible is that, so long as subsection (2) of Section 27C does not contain any specific stipulation that restricts its operation to the properties covered under Sec.27A, under no circumstances, a restrictive meaning can be assigned to the said provision, by excluding from its application, the property dealt with under Sec.9 of the Paddy Land Act. Therefore, once the property is converted/reclaimed by following the procedure under Sec.9, it will have all the consequences, as contemplated under Sec.27C, including that of subsection (2) of Section 27C. It is also to noted in this regard that, section 27C(1) starts with a non-obstante clause i.e “Notwithstanding anything contained in any other law for the time being in force……….”, which would mean that, the same would prevail over the other enactments, including the Land Tax Act, 1961. Of course, it is true that, the non-obstante Clause referred to above, is included only in subsection (1) of Section 27C and hence it was contended by the Learned Government Pleader that, it is applicable only in respect of the matters covered by subsection (1) and thus, it is confined to the creation of a new subdivision. Of course, it is true that, the non-obstante Clause referred to above, is included only in subsection (1) of Section 27C and hence it was contended by the Learned Government Pleader that, it is applicable only in respect of the matters covered by subsection (1) and thus, it is confined to the creation of a new subdivision. However, a careful reading of the section 27C as a whole would indicate that, it contemplates the procedure for change in land records, in respect of the property, which is permitted to be converted under sections 8,9,10 and 27A of the Act. Subsection (1) contains the reference of sections 8,9,10 and 27A of the Act, and the other subsections do not refer to any specific provision. Therefore, the only conclusion possible is that, Section 27C deals with the procedure to be followed in such cases, and such procedure starts with the creation of a new subdivision as provided in subsection (1), followed by the other procedure as contemplated under the remaining subsections. Thus, what is contemplated under the said provision, are the legal formalities for changing the nature of land in the records, and once the property is converted under Sections 8, 9, 10 and 27A of the Act, the creation of the new subdivision is the first step for such change, which shall be followed by the other procedure contemplated under the remaining subsections of Section 27C, irrespective of the question whether, such conversion/ reclamation was under section 9 or any other provisions as referred to above. Therefore, the contention of the learned Government Pleader that, subsection (2) of section 27C of the Paddy Land Act, cannot be made applicable to the property converted under Section 9, is not correct. This interpretation is fortified by observations made by the Hon’ble Apex Court in Sonia Bhatia v. State of U.P. and others [(1981) 2 SCC 585] , that a legislature does not waste words, without any intention and every word that is used by the legislature must be given its due import and significance. Similarly in Visitor, Amu v. K.S.Misra (2007) 8 SCC 593 , the Hon'ble Supreme Court held that; 13. ".........It is well settled principle of interpretation of the statute that it is incumbent upon the Court to avoid a construction, if reasonably permissible on the language, which will render a part of the statute devoid of any meaning or application. Similarly in Visitor, Amu v. K.S.Misra (2007) 8 SCC 593 , the Hon'ble Supreme Court held that; 13. ".........It is well settled principle of interpretation of the statute that it is incumbent upon the Court to avoid a construction, if reasonably permissible on the language, which will render a part of the statute devoid of any meaning or application. The Courts always presume that the legislature inserted every part thereof for a purpose and the legislative intent is that every part of the statute should have effect. The legislature is deemed not to waste its words or to say anything in vain and a construction which attributes redundancy to the legislature will not be accepted except for compelling reasons. It is not a sound principle of construction to brush aside words in a statute as being in apposite surplusage, if they can have appropriate application in circumstances conceivably within the contemplation of the statute." 13. Learned Government Pleader also raised a contention that, the writ petitioner is not entitled to reclaim the property under Sec.9 of the Act, in view of the fact that, the said property was purchased after the Paddy Land Act came into force. This submission is made by the learned Government Pleader, by placing reliance upon the decision rendered by this Court in Sabeena E.K v. District Collector & Ors [2022 (2) KHC 673]. However, I am not prepared to accept the said contention. 14. This is because, in this case, the petitioner was granted permission as per Ext.P2 order, as early as in the year 2012, by applying legal position that existed at the relevant time. As far as the case of Sabeena (supra) is concerned, the same was rendered in 2022 and the law declared by the same, cannot be made applicable in respect of an order already passed in 2012 and acted upon by the parties concerned. Therefore, the writ petitioner, who had already carried out the construction, acting upon Ext.P2, cannot be taken back to the position before passing of Ext.P2 order, by revisiting the said order. Rightly or wrongly, an order has been passed by the statutory authorities as evidenced by Ext.P2 as early as on 2012, and the petitioner cannot be denied the benefit of enjoying the fruits of the same, so long as the same has not been challenged or set aside by following the legal procedure. 15. Rightly or wrongly, an order has been passed by the statutory authorities as evidenced by Ext.P2 as early as on 2012, and the petitioner cannot be denied the benefit of enjoying the fruits of the same, so long as the same has not been challenged or set aside by following the legal procedure. 15. The learned Government Pleader also placed reliance upon the decision rendered by this Court in K.S. Thankachan v. District Collector [ 2017 (3) KHC 402 ] where the question regarding the definition of ‘owner’ was considered, and found that the same can only be a person who purchased the property, prior to the enactment of Paddy Land Act. However, those questions cannot be gone into at this point of time, since the statutory authorities itself granted a permission, under Sec.9, to the writ petitioner, which was relied on and further, constructions were carried on, by reclaiming the property by the petitioner. In such circumstances, in the light of the above, I do not find any justifiable reason to review the judgment already passed. 16. Yet another contention raised by the learned Government Pleader is that, as far as the classification/ reclassification of the property is concerned, the same cannot be carried out by the Tahsildar and the same can only be done in appropriate cases by the Revenue Divisional Officer. However, in the judgment sought to be reviewed, direction is issued by this Court to Tahsildar (Land Records) to invoke the power under Sec.6 of Land Tax Act in the light of Subsection (2) of Section 27C of the Act. Since subsection (2) of Section 27C of the Paddy Land Act, specifically contemplates that, the same has to be carried out by the Tahsildar(Land Records) and this Court has found that, the said provision is applicable for a property dealt with under Sec.9 also, the said application has to be dealt with by the said Tahsildar itself. On that reason also, I do not find any scope for review. Therefore, the only conclusion possible is that, the very same procedure by which the Tahsildar deals with an applicant under Sec.27A while invoking the powers under section 27C(2), has to be extended to an applicant whose property was converted/reclaimed under Sec.9 as well. Therefore, this review petition is dismissed, in the light of the above observations.