A treepasser is not a transferee within the meaning of section 51 of the Transfer of Property Act, 1882 and he is not entitled to compensation for improvements. This was decided in:
A. Daya Ram v. Shyam Sundari, (1965) 1 SCR 231
B. Krishan Prasad v. Adyanath Ghatak, AIR 1944 Pat 77
C. Bhupendra v. Pyari, (1917) 40 IC 464
D. None of the above
Answer: Option A
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