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Issues: Whether the time-limit in Section 11-A of the Land Acquisition Act, 1894 applied to acquisition proceedings under the Bangalore Development Authority Act, 1976, and whether the acquisition proceedings had lapsed on account of delay in passing the award.
Analysis: The BDA Act was treated as a special law for planned development of Bangalore and not as a mere acquisition statute. Its scheme of acquisition and lapsing was held to be self-contained, with its own provisions governing sanction of the scheme and the consequence of failure to execute it within the statutory period. Applying the principles governing incorporation and reference, the Court held that the BDA Act was neither supplemental to nor in pari materia with the Land Acquisition Act, 1894 in a manner that would attract subsequent amendments to the latter by implication. Since the State Legislature had expressly provided the period and consequence for lapse under the BDA Act, the limitation contained in Section 11-A of the Land Acquisition Act, 1894 could not be imported into BDA acquisitions. The plea of delay also failed because the appellant had contributed to the delay by prior litigation.
Conclusion: Section 11-A of the Land Acquisition Act, 1894 did not apply to acquisition proceedings under the Bangalore Development Authority Act, 1976, and the acquisition did not lapse on the ground urged.
Final Conclusion: The appeal failed and the dismissal of the challenge to the acquisition proceedings was sustained.
Ratio Decidendi: Where a special acquisition and development statute is a self-contained code and itself prescribes the period and consequence of lapse, subsequent amendments to the general Land Acquisition Act, 1894 are not imported by implication into proceedings under that special statute.