In Brief
Century Textiles operated a cotton mill on leased land under the City of Bombay Improvement Act. The Improvement Trust granted a 28-year lease from 1927–1955 under the Poorer Classes Accommodation Scheme, after which the company sought a formal conveyance of the land. The Supreme Court held that neither the Board's 1927 resolution nor the 1928 lease deed contained any obligation to convey; references to conveyance applied only to a narrow strip, not the entire block. The Court harmoniously interpreted Sections 48 and 51 of the 1925 Act: conveyance was contingent on lease terms, not automatic. Additionally, the 61-year delay before filing suit, coupled with deliberate avoidance of statutory limitation periods, rendered the claim barred by laches. The appeal was allowed and the High Court's order set aside.
The lawyer headnote and full judgment text are available to registered users.