Local authority status under land acquisition law confirmed for a market committee governed by Gujarat agricultural markets legislation.

A market committee constituted under the Gujarat Agricultural Produce Markets Act, 1963 was treated as a local authority for the second proviso to Section 6 of the Land Acquisition Act, 1894. The expression "local authority" was construed by reference to the General Clauses Act, 1897 and the relevant local law, and Section 10(2) of the Gujarat Act expressly treated the committee as a local authority. The statutory scheme also showed that a body entrusted with control or management of a local fund falls within that concept. On that basis, the acquisition challenge failed.

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Issues: Whether a market committee constituted under the Gujarat Agricultural Produce Markets Act, 1963 is a local authority for the purpose of the second proviso to Section 6 of the Land Acquisition Act, 1894, so as to sustain the declaration for acquisition.

Analysis: The expression "local authority" in the Land Acquisition Act, 1894 was to be understood with reference to the definition in the General Clauses Act, 1897 and the corresponding local law. Under Section 10(2) of the Gujarat Agricultural Produce Markets Act, 1963, the market committee was treated as a local authority. The statutory scheme also showed that a body entrusted with the control or management of a local fund fell within the concept of local authority, and the market committee answered that description.

Conclusion: The market committee was a local authority within the meaning of Section 6 of the Land Acquisition Act, 1894, and the challenge to the acquisition failed.

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