Provisional plot allotment and land-use approval: no enforceable promise, and refusal to convert land was upheld.

An allotment exercise remained provisional where the advertisement, application form, and draw expressly made allotment subject to statutory approval of land use; on that basis, no enforceable right to residential plots arose and promissory estoppel or legitimate expectation could not be invoked. The refusal to change land use from industrial to residential was upheld because it was consistent with the planning statute, the Master Plan, and the industrial development policy, and the material did not show arbitrariness or mala fides. File notings and preliminary proposals were insufficient to displace the final decision.

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Issues: (i) Whether the applicants acquired an enforceable right to allotment of residential plots on the basis of the advertisement and provisional draw, and whether promissory estoppel or legitimate expectation could be invoked. (ii) Whether the Government's refusal to sanction change of land use from industrial to residential in the Mohali focal point was arbitrary, mala fide, or otherwise liable to be struck down.

Issue (i): Whether the applicants acquired an enforceable right to allotment of residential plots on the basis of the advertisement and provisional draw, and whether promissory estoppel or legitimate expectation could be invoked.

Analysis: The application form and the later advertisement made it clear that submission of the form and earnest money, and even success in the draw, would not by themselves oblige the Corporation to allot plots. The proposed residential pockets were only tentative because the layouts had been approved subject to sanction of change of land use under the governing planning statute. The applicants were therefore aware that no final and unconditional promise had been made, and no representation was shown to have induced any detrimental alteration of position.

Conclusion: The applicants had no enforceable right to allotment, and the doctrines of promissory estoppel and legitimate expectation were not available to them.

Issue (ii): Whether the Government's refusal to sanction change of land use from industrial to residential in the Mohali focal point was arbitrary, mala fide, or otherwise liable to be struck down.

Analysis: The land had been acquired for industrial development, and the statutory scheme required use to conform to the Master Plan and prescribed procedure for change of land use. The Government's refusal was consistent with its industrialisation policy and was supported by the view that the land should remain available for industrial use rather than housing. The material relied upon did not establish that the decision was taken to favour any extraneous commercial interest, and file notings or preliminary proposals were insufficient to prove mala fides against the final decision.

Conclusion: The refusal to sanction change of land use was neither arbitrary nor mala fide and was within the Government's power.

Final Conclusion: The challenge to the refusal to convert the land for residential plots failed, and the writ petitions stood dismissed while the State's appeal succeeded.

Ratio Decidendi: Where an allotment exercise is expressly provisional and subject to statutory approval of land use, no enforceable promise or legitimate expectation arises, and a policy decision refusing change of land use will not be interfered with absent tangible proof of arbitrariness or mala fides.

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