Post-notification land purchaser cannot claim allotment benefit; equality cannot be used to demand a special concession.

A purchaser who acquires land after publication of a Section 4(1) acquisition notification is not entitled to benefit under a land allotment policy confined to persons who owned the land on that date. Such post-notification purchase is made at the purchaser's peril, and the transfer does not bind the Government once the land vests in the State free from encumbrances under Section 16. A later government clarification applied only to a narrow class of earlier applicants who had timely applications, favourable orders, and executed agreements, conditions not met here. The Article 14 challenge also failed because equality cannot be claimed to repeat a special concession or an alleged erroneous benefit.

---

---

Issues: Whether a purchaser who acquired land after publication of the Section 4(1) notification under the Land Acquisition Act, 1894 could claim benefit of the land allotment policy, and whether denial of such benefit amounted to hostile discrimination under Article 14 of the Constitution of India.

Analysis: The land policy contemplated allotment only to persons whose land had been acquired, which necessarily required ownership on the date of publication of the Section 4(1) notification. A person who purchases land after such notification does so at peril, and the alienation does not bind the Government or the beneficiary of acquisition. On possession, the land vests in the State under Section 16 free from all encumbrances. The later Government order relied upon by the appellant operated only as a limited clarification for a special category of allottees who had already applied in time, had orders passed in their favour, and had entered into agreements. The appellant did not satisfy those cumulative conditions. The Article 14 challenge also failed because the special benefit extended in a narrow class of cases could not be used to demand repetition of an alleged wrong or to claim parity with a special concession.

Conclusion: The appellant, being a subsequent purchaser after the Section 4(1) notification, was not entitled to the benefit of the land policy, and denial of allotment did not violate Article 14. The appeal was liable to fail.

Ratio Decidendi: A person who purchases land after publication of a Section 4(1) acquisition notification has no enforceable right to claim allotment or alternative site under a policy confined to owners on the date of notification, and equality cannot be invoked to perpetuate an erroneous concession granted in a special case.

---