Town planning lapse provisions are not extended by plan revision; a lapsed designation is not automatically revived.

Section 20(2) of the Gujarat Town Planning and Urban Development Act, 1976 creates a lapse of land designation if acquisition is not completed, or proceedings are not commenced, within ten years and no further steps are taken after notice within six months. Section 21, which requires periodic revision of the development plan, was read as a procedural provision that does not extend the acquisition period or revive a designation already lapsed. The interpretation preserves the owner's right under Section 20(2) and avoids rendering that lapse mechanism redundant. Revision of the development plan therefore does not automatically postpone or defeat lapse.

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Issues: Whether the lapse mechanism under Section 20(2) of the Gujarat Town Planning and Urban Development Act, 1976 is defeated or postponed merely because the development plan is under revision under Section 21 of the Act.

Analysis: The statutory scheme requires Sections 12, 17, 20 and 21 to be read together. Section 20(1) is only enabling and Section 20(2) creates a legal fiction that the designation of land lapses if the land is not acquired or acquisition proceedings are not commenced within ten years and, after notice, no further steps are taken within six months. Section 21 mandates revision of the development plan at least once in ten years and makes Sections 9 to 20 applicable to such revision only so far as may be. Those words were held to govern procedure and not to enlarge the time for acquisition or to revive a designation that has already lapsed. Accepting the contrary construction would render Section 20(2) redundant and would unlawfully curtail the owner's right created by that provision. The principles of plain construction, full effect to statutory words, and strict construction of restrictions on property use support this reading.

Conclusion: Revision of the development plan under Section 21 does not automatically extend the ten-year period under Section 20(2) or revive a lapsed designation. The owner's notice can trigger lapse, and the appellants' contrary contention fails.

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