Strict compliance for transfer of acquired land: unauthorised sale deeds and mutation could not confer title or defeat acquisition.

Land notified for acquisition could not be validly transferred under the Delhi Lands (Restriction on Transfer) Act, 1972 unless prior written permission of the competent authority was obtained and the prescribed procedure was followed. Because the appellants could not show a proper application, competent-authority approval, or statutory compliance, the exception permitting transfer of acquisition-affected land was construed strictly and the sale deeds were held incapable of conveying title. A subsequent purchaser could not defeat the acquisition proceedings and, at most, could claim compensation. The mutation based on such unlawful transfers was also without jurisdiction.

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Issues: Whether the appellants' purchases of land, effected after acquisition notifications had been issued, were valid under the Delhi Lands (Restriction on Transfer) Act, 1972 and the Land Acquisition Act, 1894, and whether the sale deeds and mutation conferred any title.

Analysis: The land stood under acquisition pursuant to notifications under Sections 4 and 6 of the Land Acquisition Act, 1894. Under the Delhi Lands (Restriction on Transfer) Act, 1972, transfer of such land could be made only with prior written permission of the competent authority, who was the Additional District Magistrate (Revenue), and registration of the transfer document was prohibited unless such permission was produced. The documents relied upon by the appellants were not shown to have been issued by the competent authority, no proper application in the prescribed manner was established, and no material was produced to show compliance with the statutory procedure. The exception permitting transfer of acquired land had to be construed strictly, and a transfer made contrary to the statute could not confer title. A subsequent purchaser could not defeat the acquisition proceedings and would, at best, be entitled only to compensation.

Conclusion: The transfers were illegal and without jurisdiction, no title passed to the appellants, and the mutation based on such transfers was also without jurisdiction.

Ratio Decidendi: Where a statute permits transfer of acquisition-affected land only on prior written permission of the competent authority, the prescribed procedure must be strictly followed; any transfer or registration made without such compliance is void and does not convey title.

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