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M/S. Ansal Properties & Infrastructure Ltd. v. State of Haryana

Civil Appeal · 2017 INSC 703Decided 3 Aug 2017
Civil Appeal No. 10017 of 2017
Justice Kurian Joseph · Justice R. Banumathi

Background

The State of Haryana had initiated land acquisition proceedings against the appellant company's land years earlier. While the matter was pending before the Supreme Court, Parliament enacted the 2013 Land Acquisition Act, which (per settled case law) causes acquisition proceedings to lapse where compensation has not been paid to the landowners within the specified period. It was undisputed in this case that compensation had never been paid, even though the State had by then already put the acquired land to use.

Decision Breakdown

The Supreme Court held that, given the admitted non-payment of compensation, the acquisition proceedings had lapsed under the settled legal position arising from the 2013 Act. Since the land had already been utilised by the State, the Court ruled that the State's only remaining option was to initiate fresh acquisition proceedings under the 2013 Act, and gave it six months to do so. The Court made clear that if the State failed to initiate fresh proceedings within that period, it would lose any claim to the land altogether. The appeal was disposed of on these terms with no order as to costs.

Lesson Learnt

Under the 2013 land acquisition law, a State's failure to pay compensation causes the original acquisition to lapse even if it has already taken possession and used the land: the State must restart the process properly within a set time or forfeit its claim entirely.

Official source (sci.gov.in)View Judgment (PDF)

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