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Supreme Court of India 2019-10-22 partly_allowed

BIHAR INDUSTRIAL AREA DEVELOPMENT AUTHORITY vs AMIT KUMAR

Bench: 2 — Deepak Gupta, Aniruddha Bose

In Brief

The Supreme Court held that when an industrial estate lessee transfers leasehold rights to another entity, the original lessor authority (BIADA) is entitled to recover unearned increase in land value, calculated on the basis of market value (circle rate) at the time of transfer, not merely allotment cost plus development charges. This prevents unjust enrichment of the allottee. The Court upheld BIADA's policy of using circle rate for valuation. Among the four consolidated appeals, the Court disposed of three cases on the legal principle (one without recovery, one with interest calculation, one with partial remand for factual findings on shareholding), and partially allowed BIADA's appeal on the law."

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Land Law Industrial Estates Lease Deed Property Transfer Administrative Law Unjust Enrichment

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