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Supreme Court of India 2020-03-06

INDORE DEVELOPMENT AUTHORITY vs MANOHARLAL & ORS. ETC

Bench: 5 — Arun Mishra, Indira Banerjee, Vineet Saran, M. R. Shah, S. Ravindra Bhat

In Brief

In this landmark 5-judge bench judgment, the Supreme Court comprehensively interpreted Section 24 of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013. The Court held that: (1) the word "or" in Section 24(2) must be read as "and"/"nor" to mean both conditions (no possession taken AND no compensation paid) must be absent for acquisition to lapse; (2) "paid" and "deposited" have different meanings – tender/offer of compensation suffices as "payment"; (3) the proviso operates as part of Section 24(2), not 24(1)(b); (4) drawing of panchnama constitutes valid mode of taking possession; (5) period of interim court orders must be excluded from the 5-year period under Section 24(2); and (6) Section 24 does not revive stale or concluded proceedings. The Court overruled earlier decisions in Pune Municipal Corporation and Shree Balaji Nagar, holding that the new interpretation better reflects Parliament's intent to balance acquisition completion with landowner protections.

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