Post-notification purchasers cannot claim land release on parity, and writ courts cannot substitute the competent authority.

A purchaser who takes an agreement to sell after a Section 4 acquisition notification acquires no enforceable title and cannot seek release of the land merely on parity, discrimination or government circulars. The article states that acquisition had already attained finality, any post-notification transfer was void against the State, and Article 14 could not be invoked to claim negative equality without a proper factual foundation showing lawful comparability. It also notes that release had to be sought before the competent authority, not granted directly by the writ court, and that circulars inconsistent with the acquisition law could not override the statute. The claimed release of land for a different use was therefore unsustainable.

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Issues: Whether the respondent society, which entered into an agreement to sell after notification under Section 4, had any enforceable right to seek release of acquired land on the basis of discrimination, parity or government circulars.

Analysis: The acquisition proceedings had attained finality, and the society's agreement to sell after the Section 4 notification did not create title. A purchaser after notification cannot challenge acquisition except on a legally sustainable independent footing, and any transfer made after the notification is void against the State. The plea of discrimination also failed because the society did not establish by proper pleadings or material that it was similarly situated to those whose land had been released. Article 14 does not permit negative equality or perpetuation of illegality. The record further showed that the society had not made a proper application to the competent authority for release, and the High Court could not itself grant release in place of the statutory authority. Government circulars contrary to the law governing acquisition could not override the statute, and land acquired for industrial development could not be diverted to residential use on the facts of the case.

Conclusion: The respondent society was not entitled to release of the land, and the challenge to acquisition and subsequent allotment failed.

Final Conclusion: The High Court's direction releasing the land was unsustainable, and the appeals succeeded.

Ratio Decidendi: A person who acquires interest in land after a Section 4 acquisition notification has no enforceable right to seek release of that land merely on parity or alleged discrimination unless a clear factual foundation shows that it is similarly situated to others lawfully favored, and a writ court cannot itself grant such release in substitution of the competent authority.

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