The State of Haryana & Anr. vs Amin Lal (Since Deceased) Through His LRs & Ors.
Background
Amin Lal and another person sued for possession of land near a national highway in Bahadurgarh, Haryana, claiming ownership through revenue records, alleging the State of Haryana and its Public Works Department had occupied the land without authorisation years earlier. The trial court decreed in favour of the plaintiffs, but the first appellate court reversed this and instead accepted the State's claim of adverse possession (long, uninterrupted occupation) and even labelled the plaintiffs "land grabbers." The Punjab & Haryana High Court, in a second appeal, restored the trial court's decree in the plaintiffs' favour, and the State appealed to the Supreme Court.
Decision Breakdown
The Supreme Court held that the State's actions (minor repairs, structures and a boundary wall built in 1980) did not meet the strict legal requirements for "adverse possession," which demands continuous, open, peaceful and hostile possession against the true owner for the full statutory period; here the State's possession lacked the necessary hostility and duration. It also held that by pleading adverse possession at all, the State had implicitly admitted the plaintiffs' ownership, and a State government cannot legally claim adverse possession against its own citizens. The Court found the first appellate court had wrongly shifted the burden of proof onto the plaintiffs and ignored revenue records, so the High Court had correctly exercised its second-appeal jurisdiction to correct that error, and the Supreme Court dismissed the State's appeal.
Lesson Learnt
A government body cannot use the doctrine of adverse possession to defeat a citizen's genuine ownership of land it has occupied without proper acquisition: merely occupying land, even for a long time, does not create ownership unless the possession is truly hostile, open and uninterrupted for the required legal period.