Land acquisition time-limit under Section 11A may apply to planning-statute acquisitions under Maharashtra town planning law.

Section 11A of the Land Acquisition Act, 1894 may extend to acquisitions under Chapter VII of the Maharashtra Regional and Town Planning Act, 1966 where the planning statute does not provide a complete code on compensation and acquisition consequences. The Court noted that earlier decisions had read Land Acquisition Act compensation provisions into similar planning statutes to preserve constitutional validity and avoid discriminatory treatment between landholders. In light of the 1984 amendments, including the award time-limit and enhanced benefits, there was no convincing basis to exclude Section 11A when the Land Acquisition Act is otherwise attracted. The earlier contrary view was treated as requiring reconsideration by a larger Bench.

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Issues: Whether the amendments made to the Land Acquisition Act, 1894 by Central Act 68 of 1984, particularly the time-limit for making the award under Section 11A, apply to acquisitions under Chapter VII of the Maharashtra Regional and Town Planning Act, 1966.

Analysis: The acquisition scheme under Chapter VII of the Maharashtra Regional and Town Planning Act, 1966 was examined in the light of the Land Acquisition Act, 1894. The Court noted that while the special town planning statute contains its own mechanism for purchase notice and declaration, it does not provide a complete code on compensation and related acquisition consequences. Earlier decisions had read the compensation provisions of the Land Acquisition Act into similar planning statutes to preserve constitutional validity and avoid hostile discrimination between landholders whose lands were acquired under different statutory routes. The Court also considered the effect of the 1984 amendments to the Land Acquisition Act, including the enhanced benefits and the statutory time-limit for making an award, and found no convincing basis to exclude Section 11A when the Act is otherwise attracted to acquisition under the planning statute. The contrary view in an earlier decision was treated as requiring reconsideration.

Conclusion: Section 11A of the Land Acquisition Act, 1894 may apply to acquisitions under Chapter VII of the Maharashtra Regional and Town Planning Act, 1966, and the earlier contrary decision requires reconsideration by a larger Bench.

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