In Brief
The Supreme Court clarified the test for deemed lapse of land acquisition proceedings under Section 24(2) of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013. Land acquired by Delhi Development Authority in 1983 was challenged decades later by landowners claiming the acquisition had lapsed due to non-payment of compensation. The Court held that deemed lapse requires BOTH conditions to be absent: (1) possession not taken, AND (2) compensation not paid. Since possession was taken and handed to DDA in 1983, the acquisition could not lapse merely for non-payment. The Court overruled prior precedent and upheld the acquisition.
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