In Brief
The Supreme Court addressed whether delays in filing special leave petitions challenging land acquisition proceedings declared lapsed under the 2013 Act should be condoned. The Court held that delay can be condoned on grounds of: (1) allegations of fraud/suppression of facts; (2) COVID-19 pandemic delays; and (3) public interest where acquisition relates to critical infrastructure (metro, hospitals). Conversely, delay cannot be condoned based on subsequent change of law alone or mere bureaucratic delays. The Court upheld the Manoharlal principle that for acquisitions to lapse, both non-payment of compensation AND non-possession must occur. Multiple case lists were created with tailored relief: some cases returned to High Court for fact-finding on fraud; others upheld under Manoharlal; remaining cases given extended timelines for fresh acquisition under the 2013 Act using Article 142 powers to serve complete justice.
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