Supreme Court Overturns High Court Ruling, Highlights Errors in Locus Standi & Allotment Validity.

The SC set aside the HC's judgment, emphasizing the need to consider statutory provisions, policy decisions, and the decision-making process. The SC found errors in the HC's assessment of locus standi, allotment validity, allegations of mala fide, and delay in filing. The appeals were allowed without costs.

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Issues Involved:
1. Locus Standi of the Respondents
2. Validity of Allotment Process and Pricing
3. Allegations of Mala Fide and Legal Malice
4. Judicial Review of Policy Decisions
5. Delay and Laches in Filing the Writ Petition

Summary:

1. Locus Standi of the Respondents:
The Board contended that the respondents had no locus standi to maintain the writ petition as the legal rights of the general public had not been infringed. The High Court failed to consider the specific pleas raised by the appellants regarding the locus standi of the respondents, who were alleged to be set up by those whose lands had been acquired.

2. Validity of Allotment Process and Pricing:
The respondents challenged the allotment of land to the Company on several grounds, including breach of statutory purposes, arbitrary and unreasonable allotment, and non-invitation of applications. The High Court quashed the allotment of land exceeding 30 acres utilized by the Company and directed the Board to recover possession of the remaining land, form industrial plots, and allot them after notifying and inviting applications. The Supreme Court found that the High Court erred in its judgment by not considering the statutory provisions and the policy decision of the State. The allotment price of Rs. 3,73,324/- per acre was not deemed arbitrary given the policy decision and circumstances.

3. Allegations of Mala Fide and Legal Malice:
The respondents alleged that the exercise of power by the Board was mala fide and suffered from legal malice. The Supreme Court held that no malice of fact was alleged in the case, and the High Court's judgment based on undue haste and price fixation lacked merit. The Court emphasized that the decision-making process, not the merit of the decision, should be scrutinized, and in the absence of legal malice, the allotment could not be interfered with.

4. Judicial Review of Policy Decisions:
The Supreme Court reiterated that judicial review should not extend to the merits of policy decisions unless there is a violation of mandatory provisions or the decision is taken for unauthorized or illegal purposes. The High Court's intervention in the policy decision of the State and the Board was deemed inappropriate as the decision-making process involved due deliberations and application of mind.

5. Delay and Laches in Filing the Writ Petition:
The Supreme Court noted that the writ petition was filed after a significant delay of one year, during which the Company had taken possession of the land and made substantial investments. The High Court failed to consider the delay and its impact on equity. The delay was considered vital, and the High Court's oversight in this regard was a manifest error.

Conclusion:
The Supreme Court set aside the High Court's judgment, emphasizing the importance of considering statutory provisions, policy decisions, and the decision-making process. The appeals were allowed, and no costs were awarded.

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