Judicial review of industrial land allotment is limited to legality and mala fides; courts will not recalculate policy choices or price.

Public interest challenges to industrial land allotment are vulnerable where the petitioner lacks bona fide public interest and the writ is delayed after third-party rights and substantial investment have arisen. The allotment made under a statutory, policy-driven Single Window mechanism was upheld because judicial review is confined to legality, fairness, and absence of mala fides; the record did not show any mandatory statutory breach, legal malice, or arbitrariness sufficient to invalidate the decision. The High Court was not justified in reworking the allotment, land price, or related directions, as those matters fell within administrative and expert discretion absent proven illegality. The appeals succeeded and the State's original allotment decision was restored.

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Issues: (i) whether the writ petition in public interest challenging allotment of industrial land was maintainable in view of locus standi and delay and laches; (ii) whether the allotment made to the industrial undertaking could be interfered with in judicial review on the grounds of alleged arbitrariness, mala fides, and alleged non-compliance with the regulatory scheme; (iii) whether the High Court was justified in reworking the allotment, price fixation, and consequential directions.

Issue (i): whether the writ petition in public interest challenging allotment of industrial land was maintainable in view of locus standi and delay and laches.

Analysis: Public interest litigation is not meant to become a vehicle for private or collateral interests. Where a challenge is made to a policy-driven allotment of State land, the Court must examine whether the petitioner is bona fide and whether any real public interest is involved. Delay is also a material consideration where third-party rights have intervened and substantial investment has already been made. A petition filed after the allotment and after the project had progressed cannot be treated as immune from the doctrine of laches merely because the land was originally public land.

Conclusion: The challenge ought to have been viewed with caution, and the delay and doubtful locus standi weighed heavily against interference.

Issue (ii): whether the allotment made to the industrial undertaking could be interfered with in judicial review on the grounds of alleged arbitrariness, mala fides, and alleged non-compliance with the regulatory scheme.

Analysis: The allotment was made in pursuance of a policy of economic development through a Single Window mechanism and after deliberation by the competent authorities. The statutory framework empowered the State to issue directions, frame regulations, and, in special cases, make allotment in consultation with the State Government. The decision to proceed under the special allotment regulation was held to be within the statutory domain. Judicial review does not permit the Court to substitute its view on the adequacy of land requirement or the wisdom of the administrative choice unless the decision is shown to be illegal, wholly arbitrary, or tainted by mala fides. The record did not establish legal malice or violation of any mandatory statutory requirement.

Conclusion: The allotment was not liable to be struck down on the grounds of arbitrariness, mala fides, or statutory invalidity.

Issue (iii): whether the High Court was justified in reworking the allotment, price fixation, and consequential directions.

Analysis: The High Court entered into the merits of the policy decision, the price fixed for the land, and the extent of land to be retained, although such matters lay primarily within administrative discretion and expert assessment. Different pricing considerations apply to large industrial allotments and to fully developed plots. The Court held that it was not open to the High Court to recalculate the price or restructure the allotment in the absence of a finding of illegality, mala fides, or breach of mandatory law. The directions for survey, partial quashing, recovery of land, and refixation of price were therefore unsustainable.

Conclusion: The impugned directions of the High Court were not justified and could not stand.

Final Conclusion: The appeals succeeded, the High Court's judgment was set aside, and the original allotment decision of the State authorities was restored.

Ratio Decidendi: In matters of industrial land allotment taken pursuant to a statutory policy and expert administrative consultation, judicial review is confined to legality, fairness, and absence of mala fides, and the Court will not substitute its own assessment of policy, pricing, or land requirement in the absence of a proved statutory violation.

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