VidhiSangh

Supreme Court of India · 14/10/2019

SHIV KUMAR & ANR. versus UNION OF INDIA & ORS.

[2019] 13 S.C.R. 695 · 2019 INSC 1142

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Summary

Purchasers who acquired land after the acquisition notification sought a declaration of lapse under the 2013 land-acquisition legislation. The Court held that a transaction void against the State could not support that claim or restore title through subsequent legislation. It overruled Manav Dharam Trust, also finding possession had been taken and that the vendor’s own title documents were inadequate.

Issues

  1. Whether post-notification purchasers could claim lapse under section 24 of the 2013 Act.
  2. Whether the claimed possession and chain of documents supported relief.

Provisions considered

Held

Result

The appeal was dismissed and refusal of the requested lapse declaration left undisturbed. Manav Dharam Trust was overruled.

Judgment PDF: Supreme Court of India, [2019] 13 S.C.R. 695.