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Issues: Whether, under Section 313 of the Delhi Municipal Corporation Act, 1957, the Corporation could impose a condition in a sanctioned layout plan requiring the owner to transfer open spaces reserved for parks and schools to the Corporation free of cost, and whether such reserved land vested in the Corporation or only gave it a right to manage the land.
Analysis: Section 313 empowers the Standing Committee to sanction a layout plan on such conditions as it may think fit, but the power must be exercised consistently with the statute and cannot be expanded to deprive the owner of title without legislative authority. The scheme of Sections 312 to 330 concerns private streets and layout regulation; it does not provide for vesting of land reserved for open space, park, school, or similar public purposes in the Corporation. Reserving land for public use may create obligations in the nature of trust and may restrict alienation by the owner, but that is distinct from a transfer of ownership. The Corporation may regulate, supervise, and manage such land in the public interest, yet it cannot insist that the land be conveyed to it free of cost in the absence of statutory provision. A condition compelling such transfer was therefore beyond the statutory power conferred by Section 313.
Conclusion: The condition requiring free transfer of the reserved land was invalid, and the Corporation had only a right of management, not ownership.
Final Conclusion: The owner's title to the reserved land was not divested by the sanctioned layout plan, though the Corporation's managerial control over the land for the benefit of the colony was recognised.
Ratio Decidendi: A statutory power to sanction a layout plan on conditions does not authorise compulsory transfer of land to a local authority free of cost unless the statute expressly provides for vesting or acquisition of ownership.