also granted for tractors or installed tubewells. Another provision of MLR 115, Section 25, gave first right of re-emption (right of first refusal to buy) to the existing tenants. In 1977, another bill the Land Reform Act, 1977, reduced the ceiling to 100 acres, although this act provided for compensation to landlords. "Analysts agree" that the implementation of land reforms under Ali Bhutto "left much to be desired." The amount of land seized and redistributed to the peasants was modest, and the reforms were not administered equitably, with implementation much more robust in the NWFP and Balochistan, where opposition to Bhutto was centered, than in provinces where his power base resided, (Sindh and Punjab). Many of Pakistan's large landlords mobilized against the reforms which they saw as "a direct challenged to their long-standing interest in maintaining political control in Pakistan's rural areas". The land reforms were attacked as "unjustly administered; and as inherently un-Islamic." After Ali Bhutto was overthrown, landlord victims of land reform appealed to "Islamic Courts" established by Bhutto's successor General Zia-ul-Haq (i.e. the Shariah Appellate Bench and Federal Shariat Court), and these, rather than the executive or legislature of Pakistan, undid much of Ali Bhutto's redistribution. According to scholar Charles H. Kennedy, the courts effectively "suspended implementation" of the land reforms, "repealed the reforms, drafted new legislation, and then interpreted the new laws' meanings". A 3-2 decision in 1989 by the Shariat Appellate Bench ruled against setting a ceiling on size of landholdings (as the Bhutto land reform had done) on the grounds that "Islam does not countenance compulsory redistribution of wealth or land for the purpose of alleviating poverty, however laudable the goal of poverty relief may be." According to barrister writing in dawn.com, "The net result of the Qazalbash Waqf v Chief Land Commissioner (The 1989 Shariat Appellate Bench decision) is that land reforms in Pakistan are now at the same level as they were in 1947, as the 1972 regulations and the 1977 act have seen their main provisions being struck down and the 1959 regulations have been repealed." A book published in 1988 sponsored by Cornell University has opposed the agricultural reforms in Pakistan, arguing it will contribute to the already unsustainable population growth in the country. Shrinking farm sizes The average farm size has steadily declined as following: 5.3 hectares in 1971 3.1 hectares in 2000 2.6 hectares in 2010 Impacts of