Land acquisition delay does not necessarily quash proceedings; courts may grant additional compensation instead of upsetting completed projects.

Prolonged, unexplained delay in land acquisition after a Section 6 declaration was held inconsistent with the statutory duty to complete acquisition within a reasonable time and with the requirement to pay market value. The acquisition was not quashed because possession had been taken, public projects had proceeded, and third-party interests had intervened, but the landholders were granted additional compensation in lieu of setting aside the proceedings. Section 11-A was held not to validate earlier inaction and was treated as inapplicable where the awards had already been made before the amendment came into force.

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Issues: (i) Whether prolonged inaction in land acquisition proceedings after the Section 6 declaration justified quashing the acquisition or warranted a modified relief by way of additional compensation; (ii) Whether Section 11-A of the Land Acquisition Act validated the prior delay in completing the proceedings.

Issue (i): Whether prolonged inaction in land acquisition proceedings after the Section 6 declaration justified quashing the acquisition or warranted a modified relief by way of additional compensation.

Analysis: The scheme of the Land Acquisition Act contemplates expeditious completion of acquisition, and where no time-limit is fixed for exercise of statutory power, that power must be exercised within a reasonable time. Unexplained delay of more than a decade after the declarations under Section 6, coupled with assessment of compensation by reference to the much earlier dates of the Section 4 notifications, was held to be inconsistent with the statutory and constitutional requirement of payment of market value. At the same time, quashing the proceedings was considered inappropriate because possession had been taken in many cases, public projects had been implemented, and third-party interests had intervened.

Conclusion: The acquisition proceedings were not quashed, but the petitioners were held entitled to additional compensation calculated at 12% per annum after expiry of two years from 23 August 1974 until the date of the award.

Issue (ii): Whether Section 11-A of the Land Acquisition Act validated the prior delay in completing the proceedings.

Analysis: Section 11-A, introduced by the Land Acquisition (Amendment) Act, 1984, was construed as laying down a fresh mandate and not as validating earlier inaction. The proviso was treated as an exception for pre-amendment declarations and not as a curative provision condoning delay already suffered. It was further noted that the section had no application where awards had already been made before the amendment came into force.

Conclusion: Section 11-A did not validate the earlier delay and was not applicable to the proceedings in question.

Final Conclusion: The Court balanced the prejudice caused to the landholders against the public interest in completed acquisitions and granted monetary relief instead of setting aside the proceedings.

Ratio Decidendi: Where land acquisition proceedings are allowed to remain pending for an unreasonably long period after declaration, the Court may refuse to quash the acquisition on public-interest grounds yet grant additional compensation in exercise of writ jurisdiction; a later statutory time-limit does not retrospectively validate prior unexplained delay.

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