Subsequent purchaser cannot challenge land acquisition after Section 4 notice, and vested land cannot be reconveyed as of right.

A subsequent purchaser after publication of a Section 4 notification acquires no better title than the vendor and has no locus to challenge the acquisition; at most, such a purchaser may seek compensation. Quashing of Section 6 proceedings in other litigation, or later non-use of the land, does not by itself lapse a valid acquisition or create a right to reconveyance once possession has been taken and the land has vested in the State under Sections 16 and 17(2). Equitable relief was also refused because the claim rested on inconsistent pleas and misleading documents.

---

---

Issues: (i) whether a subsequent purchaser after issuance of a notification under Section 4 of the Land Acquisition Act, 1894 can challenge the acquisition proceedings; (ii) whether quashing of the declaration under Section 6 in other proceedings or non-use of the acquired land entitled the appellants to treat the acquisition as lapsed or seek reconveyance after vesting; and (iii) whether the appellants were entitled to any equitable relief in view of the inconsistent pleas and the use of forged and misleading documents.

Issue (i): whether a subsequent purchaser after issuance of a notification under Section 4 of the Land Acquisition Act, 1894 can challenge the acquisition proceedings.

Analysis: A person who purchases land after publication of a Section 4 notification acquires no better title than the vendor and purchases at his own peril. The legal consequence of the notification is public notice of intended acquisition, and any alienation thereafter is void against the State. Such a purchaser may, at the highest, claim compensation in the shoes of the erstwhile owner, but cannot challenge the validity of the acquisition proceedings.

Conclusion: The appellants, being subsequent purchasers, had no locus to challenge the acquisition proceedings.

Issue (ii): whether quashing of the declaration under Section 6 in other proceedings or non-use of the acquired land entitled the appellants to treat the acquisition as lapsed or seek reconveyance after vesting.

Analysis: The benefit of quashing of acquisition proceedings in a different case does not automatically extend to persons who never objected under Section 5-A or challenged the acquisition for their own land. Once possession is taken and the land vests in the State under Sections 16 and 17(2), it cannot be divested by resort to Section 48 or the General Clauses Act. Non-utilisation of the land for the original purpose does not undo a valid vesting, and reconveyance cannot be claimed as of right after vesting.

Conclusion: The acquisition did not lapse in favour of the appellants, and no right to reconveyance or restitution arose.

Issue (iii): whether the appellants were entitled to any equitable relief in view of the inconsistent pleas and the use of forged and misleading documents.

Analysis: The appellants sought mutually inconsistent reliefs, claiming both that the acquisition had lapsed and that the land be reconveyed. They also relied on forged or misleading documents and attempted to obtain advantages through unfair means. A litigant who suppresses material facts, uses fabricated documents, or approbates and reprobates is not entitled to equitable relief under writ jurisdiction.

Conclusion: The appellants were disentitled to relief on equitable grounds.

Final Conclusion: The acquisition remained valid against the suit land, the appellants could not challenge it as subsequent purchasers, and no reconveyance or other equitable relief was permissible; the appeals therefore failed.

Ratio Decidendi: A subsequent purchaser after a Section 4 notification cannot challenge acquisition proceedings, and once land has vested in the State after possession is taken, it cannot be divested or reconveyed merely because other proceedings were quashed or the land was later not used for the stated purpose.

---