Govt. of NCT of Delhi Thr. Its Secretary, Land and Building Department vs M/S. K.L. Rathi Steels Ltd.
Background
This case arose out of years of litigation over whether old land acquisitions in Delhi (including land belonging to K.L. Rathi Steels Ltd.) had "lapsed" under Section 24(2) of the 2013 Land Acquisition Act, based on the Supreme Court's 2014 ruling in Pune Municipal Corporation. That ruling was later doubted, declared per incuriam, and finally overruled by a 5-judge Constitution Bench in Indore Development Authority v. Manoharlal. Landowners and authorities whose cases had earlier been decided based on Pune Municipal Corporation then filed review petitions asking the Court to revisit those final decisions in light of the changed law. A 2-judge Division Bench hearing these review petitions gave a split verdict: the presiding judge allowed the reviews in the "larger public interest," while the companion judge dissented, holding that the Civil Procedure Code's rules on review (specifically the Explanation to Order XLVII Rule 1) expressly bar reopening a final judgment merely because the law was later changed by a subsequent overruling decision. This disagreement was referred to a larger 3-judge bench, resulting in the present judgment.
Decision Breakdown
The 3-judge bench agreed with the dissenting judge, holding that a review petition cannot succeed merely because the legal position was later overturned by a subsequent decision: the Explanation to Order XLVII Rule 1 CPC specifically excludes "a subsequent decision on a question of law" as a ground for review, and finality of judgments (the principle that litigation must end) is a matter of public policy. On that basis, the review petitions were technically not maintainable and would ordinarily have been dismissed outright. However, exercising its extraordinary powers under Article 142 of the Constitution to do "complete justice," and noting that connected appeals involving the same underlying land-acquisition dispute were pending before it, the Court crafted a special one-time remedy: it gave the government authorities one additional year (from 1 August 2024) to initiate fresh land acquisition proceedings for the affected lands, directed status quo on possession and land use in the interim, and relaxed several procedural requirements of the 2013 Act (such as the Social Impact Assessment study) given that the lands were largely non-agricultural/urban and already in use. Several individual cases involving disputed facts (such as claims of fraudulent property transfers by "subsequent purchasers") were separated out for individual assessment rather than being covered by this common order.
Lesson Learnt
A final Supreme Court judgment generally cannot be reopened through a review petition simply because the law was changed afterward by a later ruling: finality of litigation is a deliberate legal policy, not an oversight; but in matters of significant public interest affecting many similarly-placed parties, the Court can still use its special constitutional power (Article 142) to fashion a practical, one-time solution instead of leaving everyone to relitigate from scratch.