STATE OF HARYANA & OTHERS versus AALAMGIR & OTHERS

Citation: [2025] 3 S.C.R. 1460 · Decided: 18-03-2025 · Supreme Court of India · Bench: B.V. NAGARATHNA, SATISH CHANDRA SHARMA · Disposal: Disposed off

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Judgment (excerpt)

[2025] 3 S.C.R. 1460 : 2025 INSC 407
State of Haryana & Others 
v. 
Aalamgir & Others
(Civil Appeal No. 4052 of 2025)
18 March 2025
[B.V. Nagarathna and Satish Chandra Sharma, JJ.]
Issue for Consideration
The present appeals assail the orders passed by the Punjab 
and Haryana High Court in several writ petitions in respect of 
acquisition of various parcels of land from time to time by issuance 
of notifications u/ss.4 and 6 of the Land Acquisition Act, 1894.
Headnotes†
Land Acquisition Act, 1894 – ss.4 and 6 – Right to Fair 
Compensation and Transparency in Land Acquisition, 
Rehabilitation and Resettlement Act, 2013 – s.24(2) – The 
respondents land owners/subsequent purchasers have 
assailed the acquisition process – The validity of the 
acquisition were raised in the various writ petitions filed by 
them – However, pursuant to the enforcement of 2013 Act, fresh 
writ petitions were filed seeking relief under sub-section (2) 
of s.24 of the 2013 Act – In some of the impugned judgments, 
the High Court has followed the earlier judgment of this 
Court in Pune Municipal Corporation and has granted relief 
to the respondents-land owners/subsequent purchasers  – 
Correctness:
Held: 1. In the instant case, if these appeals have to be considered 
on merits then the judgment passed by the five-Judge Bench of 
this Court in the case of Indore Development Authority would have 
to be applied to the facts of each case – In the circumstances, this 
Court finds it just and proper to set aside the impugned orders and 
remand these matters to the High Court for reconsideration of the 
Writ Petitions filed by the respondents land owners/subsequent 
purchasers and to dispose of those Writ Petitions on the basis of 
the recent judgment of this Court in Indore Development Authority 
by applying the ratio and the observations of the said judgment 
to the facts of each case as they emanate in each of the cases. 
[Paras 7, 9]
[2025] 3 S.C.R. 
1461
State of Haryana & Others v. Aalamgir & Others
2. Since this Court is remanding the matters to the High Court, the 
order of status quo which were prevailing in those cases may be 
continued till the disposal of the writ petitions by the High Court. 
[Para 11]
3. Further, liberty reserved to the respondents-land owners/
subsequent purchasers to raise all available contentions with regard 
to the validity of the acquisition which have been undertaken under 
the LA Act of 1894 before the High Court. [Para 14]
4. Considering the long lapse of time between the quashing of the 
acquisition or a declaration that they have lapsed and the matters 
now being remanded to the High court for reconsideration and 
there being subsequent developments with regard to the subject 
land in question, liberty may be reserved to the respondents-land 
owners/subsequent purchasers to raise all contentions on the basis 
of equity and in accordance with law. [Para 16]
5. In certain cases there may be death of the respondents-land 
owners/subsequent purchasers and there has been no application 
filed for substitution of the deceased before this Court – The High 
Court directed to issue fresh notices to the respondents-land 
owners/subsequent purchasers if they have not appeared before 
the High Court in those cases. [Para 17]
6. If the respondents-land owners/subsequent purchasers wish 
to take advantage of the concessions or the consent orders 
made by the High Court on the basis of the concessions made 
by the State, the same shall be considered having regard to the 
respective contentions advanced at the Bar and in accordance 
with law. [Para 19]
Case Law Cited
Indore Development Authority v. Manoharlal [2020] 3 SCR 1 : 
(2020) 8 SCC 129 – followed.
Pune Municipal Corporation v. Harakchand Misirimal Solanki [2014] 
1 SCR 783 : (2014) 3 SCC 183 – referred to.
List of Acts
Land Acquisition Act, 1894; Right to Fair Compensation and 
Transparency in Land Acquisition, Rehabilitation and Resettlement 
Act, 2013.
1462
[2025] 3 S.C.R.
Supreme Court Reports
List of Keywords
Land acquisition; Acquisition process; Validity of the acquisition; 
Section 24 of the Right to Fair Compensation and Transparency in 
Land Acquisition, Rehabilitation and Resettlement Act, 2013; Land 
owners; Subsequent purchasers; Order of status quo; Subsequent 
development in respect of land acquired; Death of land owners; 
Fresh Notices; Remanding of matters to High Court; Advantage of the 
concessions; Consent orders; Indore Development Authority c

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