Illegal land allotment cannot be claimed as equality; vested land transferred after acquisition creates no enforceable purchaser rights.

Land acquired and vested in the State extinguished the erstwhile owner's title, so later sale deeds, ministerial directions, or a claimed policy could not create any enforceable right to allotment or possession for purchasers from that owner. Article 14 also could not be used to demand repetition of an illegal allotment, because equality does not require perpetuation of an ultra vires benefit. However, considering the long lapse of time, practical hardship, and the equities of the matter, the Court did not fully unsettle the relief but modified it by directing allotment under another scheme on uniform terms.

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Issues: (i) Whether purchasers from the erstwhile owner, after acquisition notification and vesting of the land in the State, acquired any enforceable right to allotment or possession on the basis of sale deeds, ministerial directions, or an asserted Government policy; (ii) whether Article 14 could be invoked to compel the authority to repeat or perpetuate an illegal allotment made in favour of others; (iii) whether the Court should disturb the High Court's relief after considering the long lapse of time and hardship.

Issue (i): Whether purchasers from the erstwhile owner, after acquisition notification and vesting of the land in the State, acquired any enforceable right to allotment or possession on the basis of sale deeds, ministerial directions, or an asserted Government policy.

Analysis: On publication of the acquisition notification and vesting of the land under the Act, the erstwhile owner's title stood extinguished and encumbrances created thereafter could not bind the State. The sale deeds executed by the erstwhile owner after acquisition could not convey title, and the description of the purchasers as sub-awardees or nominees did not create any legal interest. The so-called policy relied upon was founded on the same void premise that had already been declared legally unsustainable. Rule-based or executive directions could not expand the limited statutory power under the land acquisition framework into a general power to confer acquired land on private parties.

Conclusion: No enforceable right to allotment or possession arose in favour of the respondents.

Issue (ii): Whether Article 14 could be invoked to compel the authority to repeat or perpetuate an illegal allotment made in favour of others.

Analysis: Equality protection presupposes a legally sustainable right and a valid basis for comparison. A wrong or illegal benefit conferred on some persons cannot be used as a foundation to claim the same illegal benefit by others. The doctrine of equality does not require repetition of illegality, nor can judicial process be used to legitimise ultra vires acts merely because similar errors were committed in other cases. The alleged parity was thus with transactions that were themselves contrary to law and could not furnish a legal premise for relief.

Conclusion: Article 14 could not be invoked to enforce parity with illegal allotments, and the claim on that basis failed.

Issue (iii): Whether the Court should disturb the High Court's relief after considering the long lapse of time and hardship.

Analysis: Although the High Court's direction was found to be legally unsound, the Court took note of the long lapse of time, the practical difficulty of securing residential plots in the meantime, and the possibility that the respondents had not procured the allotments by fraudulent means. Balancing the need to correct illegality with the peculiar equities of the case, the Court chose not to unsettle the existing directions altogether, but to modify the relief by directing allotment in another scheme at a uniform area and at the earlier prevailing rate.

Conclusion: The High Court's relief was not fully disturbed and was modified in exercise of discretion.

Final Conclusion: The judgment affirms that illegal allotments under a void premise cannot be justified by Article 14, but in the peculiar facts the existing relief was substantially retained with modification, while one connected appeal was dismissed.

Ratio Decidendi: Equality cannot be claimed to perpetuate or repeat an illegality, and an allotment founded on a void statutory or executive act confers no enforceable right.

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