Broad interpretation of rehabilitation upheld for land acquisition involving settlement of displaced persons and allied medical facilities.

Under the West Bengal Land Development and Planning Act, 1948, settlement of immigrants and displaced persons was treated as a public purpose, and "settlement" and "re-settlement" were regarded as materially equivalent in that context. Rehabilitation was construed broadly to include amenities needed for effective resettlement, not merely shelter, so a proposed hospital for crippled children could fall within the same public purpose when linked to displaced persons and their families. The text also states that compensation was tied to market value on the Section 4 notification date, with a special limitation for such acquisitions, and that interested persons cannot readily rely on internal correspondence to displace the notified public purpose.

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Issues: Whether land acquisition under the West Bengal Land Development and Planning Act, 1948 was vitiated because the notified public purpose of settlement of immigrants was said to differ from the later proposal to use part of the land for a hospital for crippled children, and whether such use fell outside the statutory concept of rehabilitation and settlement.

Analysis: The statutory scheme treated the settlement of immigrants who had migrated into West Bengal on account of circumstances beyond their control as a public purpose. The Act also linked compensation to the market value on the date of the Section 4 notification, with a special limitation where acquisition was for that public purpose. The words "settlement" and "re-settlement" were held to be materially equivalent in the context of refugees and displaced persons. The subsequent correspondence showed that the proposed hospital was part of the rehabilitation effort and was intended to provide medical facilities to displaced persons and their children. Rehabilitation was understood broadly and not as mere provision of shelter, but as including amenities necessary for effective resettlement. The Court also held that persons interested in acquired land cannot lightly go behind a notification and rely on internal correspondence, especially when the notified purpose itself is a public purpose.

Conclusion: The acquisition was not vitiated by bad faith or colourable exercise of power, and the proposed hospital for crippled children fell within the concept of settlement and rehabilitation of displaced persons.

Final Conclusion: The challenge to the acquisition failed, and the judgment of the Division Bench was displaced in favour of restoration of the Single Judge's decision.

Ratio Decidendi: Where the notified purpose is the settlement or rehabilitation of displaced persons, later provision of allied amenities such as a hospital for crippled children may still fall within that public purpose, and the acquisition cannot be invalidated merely because the internal administrative correspondence reveals such an ancillary use.

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