https://www.scconline.com/blog/post/2023/02/18/section-51-tp-act-applies-on-transferee-who-makes-improvements-in-good-faith-on-a-property-believing-himself-to-be-its-absolute-owner-supreme-court-legal-research-legal-news-upd/
Section 51 of the Transfer of Property Act applies on transferee who makes improvements in good faith on a property, believing himself to be its absolute owner: Supreme Court