Section 5(1)(a) in The Kosi Area (Restoration of Lands to Raiyats) Act, 1951
(a)that he has constructed any building or other structure of a permanent nature or planted any garden on the holding or any portion thereof before the date of the commencement of this Act and that such building, structure or garden is of such a value that the restoration of the land covered by such building, structure or garden will be unfair; and