Punjab & Haryana High Court, Chandigarh
Citation(2020) 3 SCC 412
CourtSupreme Court of India (Constitution Bench)
Date6 March 2020
Year2020
BenchArun Mishra, Indira Banerjee, Vineet Saran, M.R. Shah, S. Ravindra Bhat JJ.
Acts/ArticlesRFCTLARR Act 2013 Section 24, Land Acquisition Act 1894
CategoryConstitutional Law, Property & Land Law

Key Principle Established

Section 24 of the Right to Fair Compensation Act 2013 (RFCTLARR Act) — land acquisition lapses only if both conditions met: (a) award not made AND (b) compensation not paid/deposited. "Or" in the section to be read as "and".

Brief Facts

A major controversy arose over interpretation of Section 24(2) of the RFCTLARR Act, 2013 — whether pending land acquisition proceedings under the old 1894 Act lapse if compensation was not paid/deposited, even if an award had been made.

Ratio Decidendi

The Constitution Bench overruled the earlier Pune Municipal Corporation (2014) decision and held:

  • The word “or” in Section 24(2) must be read as “and”
  • Land acquisition lapses only if both conditions are met: award not made AND compensation not paid/deposited
  • If either an award has been made OR compensation has been deposited, the acquisition does not lapse
  • Deposit in government treasury constitutes valid payment/deposit of compensation

Impact & Significance

This Constitution Bench decision has massive implications for land acquisition across India, including thousands of pending acquisitions in Haryana. It reversed a line of judgments that had allowed landowners to reclaim acquired land, and settled the law definitively on when old acquisitions survive under the new Act.

Tags & Related Topics

Constitutional Law Property & Land Law RFCTLARR Act 2013 Section 24 Land Acquisition Act 1894
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Disclaimer

This judgment summary is for educational and research purposes. While care has been taken to accurately represent the ratio and findings, for authoritative reference always consult the original judgment text from official sources (SCC Online, AIR, Manupatra, or court websites).

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