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Sita Ram v. State of Haryana

Civil Appeal · Neutral citation not assigned (Civil Appeal No. 10532 of 2014)Decided 25 Nov 2014
Civil Appeal No. 10532 of 2014
Justice V. Gopala Gowda · Justice Adarsh Kumar Goel

Background

Sita Ram challenged acquisition of land and buildings used for his fireworks factory, arguing that the retained land was needed for the licensed safety distance and that comparable industries had been released. The High Court rejected his challenge, but court orders preserved his possession while the appeal continued. He then sought lapse under section 24(2) of the 2013 land-acquisition law.

Decision Breakdown

The Supreme Court allowed his application and quashed the acquisition proceedings for his land and buildings. The relevant award dated October 8, 2003 was more than five years old when the 2013 Act commenced, while he remained in possession and compensation had not been paid. The State acknowledged that his compensation was deposited in court only on April 9, 2014. Applying the Pune Municipal Corporation and Sree Balaji decisions then governing section 24(2), the Court held the acquisition had lapsed, without excluding the periods of interim protection. The operative relief rested on lapse rather than resolving the factory-exemption arguments.

Lesson Learnt

Sita Ram obtained release from this acquisition under the interpretation applied in 2014, rather than a general exemption for fireworks factories. The lapse and court-stay rules relied on here were subsequently changed and should not be treated as current law.

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

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