Land acquisition challenges must be brought promptly; finalised proceedings can be defeated by delay and laches.

A challenge to land acquisition proceedings under the Land Acquisition Act, 1894 must be brought within a reasonable time. Once the notification, declaration, award and taking of possession have occurred, the acquisition acquires finality and a belated writ petition may be refused on laches. The Court need not exercise extraordinary writ jurisdiction where the claimant has slept over rights and offers no sufficient explanation for the delay, even if the acquisition is alleged to be void. On the stated facts, prior knowledge of the acquisition and the absence of a credible justification for the delay meant the challenge was not maintainable.

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Issues: Whether acquisition proceedings under the Land Acquisition Act, 1894 could be challenged after an inordinate and unexplained delay, once the notification, declaration, award and possession had already taken effect.

Analysis: A challenge to a notification under Section 4 or declaration under Section 6 of the Land Acquisition Act, 1894 must be brought within a reasonable time. When acquisition proceedings are allowed to progress to the stage of award and taking of possession, the proceedings acquire finality and a belated writ petition is vulnerable to dismissal on the ground of laches. Even where the validity of the proceedings is attacked as void, the extraordinary jurisdiction of the Court need not be exercised if the party has slept over its rights and approached the Court after the acquisition has substantially concluded. On the facts, the petitioners had knowledge of the acquisition and offered no sufficient basis to overcome the delay.

Conclusion: The belated challenge to the acquisition proceedings was not maintainable and was rightly rejected on the ground of delay and laches.

Ratio Decidendi: A challenge to land acquisition proceedings must be made within a reasonable time before the proceedings attain finality, and inordinate delay bars discretionary relief under writ jurisdiction even if the action is alleged to be void.

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