In Brief
The Madhya Pradesh Housing Board developed a residential colony (Indira Nagar) and later sought to modify the approved layout plan, converting 1.52 hectares designated for a commercial shopping complex into residential plots. A High Court judgment quashed this modification and declared related sales void, relying on promissory estoppel principles and concerns about allottees who paid extra for plots near amenities. The Supreme Court reversed this, holding that layout plan modifications are permissible under applicable planning law if they comply with statutory procedure and development norms. The Court emphasized that delay of seven years in challenging the modification, combined with creation of bonafide third-party rights, barred the writ petition. It directed that unsold residential plots be reserved for public amenities.
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