Supreme Court Remands Multiple Haryana Land-Acquisition Writs to High Court; Condones Delays with Staged Costs and Keeps Status Quo

A bench of Justice B.V. Nagarathna and Justice Satish Chandra Sharma heard consolidated appeals arising out of numerous writ petitions before the Punjab and Haryana High Court that challenged acquisitions made under Sections 4 and 6 of the Land Acquisition Act, 1894 and invoked Section 24(2) of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013. The appeals were filed by the State of Haryana and others against orders in which various landowners and subsequent purchasers had secured relief from acquisition processes or declarations of lapse.

The Court set aside the impugned High Court orders and remanded the matters for fresh consideration in light of the five-Judge decision in Indore Development Authority v. Manoharlal (2020). It allowed applications for condonation of delay in filing applications to set aside abatement, and permitted substitution of legal representatives where respondents had died, observing that “Abatement is set-aside.” The Court directed that many extant orders of status quo shall continue until the High Court disposed of the writ petitions. It also prescribed a graded schedule of costs for condonation of delay (ranging from Rs.5,000 to Rs.50,000 depending on days of delay) and ordered that the amounts be deposited with the Supreme Court Mediation Centre by 05.05.2025. The Court emphasised that it did not decide merits and remitted factual and legal questions to the High Court for determination on the basis of the Indore Development Authority ratio. The Court, in its reasoning, observed: “Section 24(2) of the 2013 Act does not give rise to new cause of action to question the legality of concluded proceedings of land acquisition. Section 24 applies to a proceeding pending on the date of enforcement of the 2013 Act i.e. 1-1-2014. It does not revive stale and time-barred claims and does not reopen concluded proceedings nor allow landowners to question the legality of mode of taking possession to reopen proceedings or mode of deposit of compensation in the treasury instead of court to invalidate acquisition.” The Court further recorded that “we have not made any observation on the merits of the matters.”

Background The disputes arose from multiple notifications and acquisition proceedings initiated under the Land Acquisition Act, 1894. Landowners and subsequent purchasers had approached the High Court challenging acquisition steps and, post-enforcement of the 2013 Act, had sought relief under Section 24(2) alleging lapse of acquisition where authorities had not taken possession or paid compensation for five years prior to 1-1-2014. Several High Court orders granted relief on the basis of this Court’s earlier decision in Pune Municipal Corporation v. Harakchand Misirimal Solanki (2014). Subsequently, a five-Judge Bench in Indore Development Authority overruled Pune Municipal Corporation and clarified the scope of Section 24(2), including that the word “or” between possession and compensation must be read conjunctively in specific factual contours and that tendering of compensation under Section 31(1) completed the obligation.

The State of Haryana challenged the High Court orders arising from the pre- and post-2014 proceedings. This Court noted that application-specific factual determinations (such as whether possession had been taken, whether compensation was tendered or deposited, and the effect of interim orders) required perusal of original records and re-adjudication. Consequently, the Supreme Court remanded all the matters to the High Court to apply the ratio in Indore Development Authority to the facts of each case, while preserving status quo orders in those matters where such orders existed. The Court allowed condonation applications for delay in filing applications for set-aside of abatement and prescribed costs according to a graduated scale; it directed deposit of the imposed costs by 05.05.2025 and warned that non-deposit would preclude the High Court from hearing the appellants until receipts were filed. The Court also reserved liberty to respondents to raise, before the High Court, any other contentions regarding validity of acquisition, including equitable or third‑party developments on the lands, and permitted impleadment or substitution of legal heirs where necessary.

Case Details: Case No.: 2025 INSC 407 (and consolidated Civil Appeals arising out of multiple SLPs listed in the order) Case Title: State of Haryana & Others v. Aalamgir & Others Appearances: For the Petitioner(s): Learned Solicitor General (appeared); Mr. Akshay Amritanshu and Mr. Samar Vijay Singh (noddal counsel for the State) For the Respondent(s): Mrs. Vanshaja Shukla and Ms. Diksha Rai Goswami (counsel for respondents/landowners)

The appeals were disposed of by order dated March 18, 2025, with remand and directions as recorded above.