In Brief
The Supreme Court upheld the cancellation of 125 acres of industrial land allotted to Kamla Nehru Memorial Trust (KNMT) by the Uttar Pradesh State Industrial Development Corporation. KNMT defaulted on payment installments and failed to submit documents required for lease deed execution. UPSIDC issued three notices (14.12.2004, 14.12.2005, and 13.11.2006) before cancellation. The Court held that a communication constitutes a valid legal notice based on substance—not formal title—if it conveys facts, legal breach, and intent to pursue remedies. The notices satisfied this test. KNMT's claim that UPSIDC frustrated the contract by failing to demarcate land or deliver possession was rejected: UPSIDC had demarcated the land, and possession required prior lease deed registration. However, the Court criticized the original non-transparent allotment and directed future allocations to follow transparent, competitive procedures respecting the Public Trust Doctrine.
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