The term Jalkar is ambiguous, not explicit. It may mean a grant of a right of fishery or it may mean the grant of a sheet of water together with the subsoil, whether the one or the other must be decided upon the construction of the original grant if available or must be determined with regard to the subsequent history of the property. A Jalkar right is an immovable property within the meaning of the General clauses Act. This is a profit of pendre. The holder of jalkar right is not a non- agricultural tenant.
Unless the boundaries in a grant of a jalkar clearly indicate the contrary, the mere use of the word jalkar would not ordinarily include rights of fishery in tidal navigable rivers. ….. [11c. 434 (FB) per Pirnseo and pigot, JJ]