Public land allotments without transparency or planning compliance are invalid, though relief may be tailored for completed developments.

A public development authority cannot dispose of reserved developable land by bulk sale in a manner inconsistent with the statutory planning framework and public purpose governing the township. Allotments made below reserve price, without transparency or genuine competition, and through undisclosed private interests were treated as invalid for want of probity and fairness; where substantial construction and third-party rights had since arisen, relief could be moulded plot-wise to preserve innocent interests while protecting the authority's entitlement to the reserve price.

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Issues: (i) Whether CIDCO could lawfully resort to bulk sale of developable land and allot it without complying with the statutory planning framework and without the approval and control required under the governing development regime. (ii) Whether the impugned allotments, made at rates below the reserve price and through a process marked by lack of transparency, non-advertisement, and undisclosed private interests, were valid. (iii) What relief should follow where the allotments were found vitiated but substantial construction and third-party interests had subsequently come into existence in respect of some of the plots.

Issue (i): Whether CIDCO could lawfully resort to bulk sale of developable land and allot it without complying with the statutory planning framework and without the approval and control required under the governing development regime.

Analysis: CIDCO was constituted for planned development of the township and was expected to act on a no-profit-no-loss basis in furtherance of public objects. The remaining developable land was intended to be used in accordance with the development plan to be sanctioned by the State Government, and bulk disposal of such land for money-making purposes was inconsistent with that object. The Court held that development planning is central to orderly urban growth, ecological balance, and planned distribution of land use, and that disposal of the leftover land by bulk sale in favour of builders was not a policy choice insulated from judicial review when it ran contrary to the statutory and public purpose framework governing CIDCO.

Conclusion: Bulk sale of the land, as undertaken, was not justified in law or in public interest.

Issue (ii): Whether the impugned allotments, made at rates below the reserve price and through a process marked by lack of transparency, non-advertisement, and undisclosed private interests, were valid.

Analysis: The allotments were held to be tainted by serious procedural and substantive infirmities. The records showed departure from the notified reserve price, absence of proper approval at the appropriate level, and allotments made without affording a genuine opportunity of competition. The Court also found that certain entities were merely cloaks for the interests of a CIDCO director and his family members, creating an impermissible conflict between public office and private gain. These circumstances vitiated the transactions and supported the conclusion that the sales could not stand scrutiny under the standards of probity, transparency, and fairness expected of a public authority.

Conclusion: The impugned allotments were invalid and vitiated.

Issue (iii): What relief should follow where the allotments were found vitiated but substantial construction and third-party interests had subsequently come into existence in respect of some of the plots.

Analysis: The Court distinguished between the affected allottees on the basis of subsequent events. Where substantial construction and third-party rights had arisen, outright resumption would cause disproportionate hardship, and the relief was moulded to protect innocent purchasers while preserving the public authority's entitlement to the reserve price. Where no such irreversible situation existed, the land was directed to revert to CIDCO. The relief was therefore adjusted plot-wise to balance legality, equity, and the consequences of subsequent developments.

Conclusion: Relief was moulded partly by sustaining annulment and partly by protecting completed or substantially developed interests on terms.

Final Conclusion: The impugned bulk sales were upheld as unlawful in principle, but the operative relief was tailored according to the extent of development and third-party consequences, with land reverting in some cases and monetary adjustment ordered in others.

Ratio Decidendi: A public development authority cannot dispose of reserved developable land by bulk sale in a manner inconsistent with the statutory planning regime and public purpose, and allotments obtained through non-transparent procedures, below-reserve pricing, or conflict of interest are liable to be invalidated, though relief may be moulded to account for subsequent irreversible construction and third-party rights.

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