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Supreme Court of India 2024-07-10 allowed

New Okhla Industrial Development Authority … vs Darshan Lal Bohra & Ors

Bench: 2 — Surya Kant, K.V. Viswanathan

In Brief

NOIDA initiated land acquisition proceedings in Gautam Budh Nagar in 2013, ultimately acquiring 81.819 hectares. Landowners filed Section 5A objections; the Collector dismissed them and issued a Section 6 declaration in 2015. The High Court quashed the declaration, finding the Collector failed to properly hear objectors and mechanically rejected objections. The Supreme Court allowed NOIDA's appeal, holding: (1) only those who filed objections have statutory right to be heard; (2) acceptance of compensation without protest amounts to waiver; (3) grouping similar objections for common disposal is permissible; (4) presumptions favour regularity of official procedure; and (5) when acquisition substantially attains finality with most landowners accepting compensation and significant development expenditure made, minor procedural lapses do not vitiate acquisition. The Court upheld the acquisition while directing payment of pending compensation and permitting claims for enhancement under the 2013 Act.

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Land Acquisition Administrative Procedure Eminent Domain Property Rights Constitutional Law Statutory Procedure Public Purpose Compensation

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