Chapter XX-C compulsory purchase review is limited to relevant material, fair hearing, and timely challenge in writ jurisdiction.
Proceedings under Chapter XX-C of the Income-tax Act are described as permitting judicial review only on limited grounds: the authority must consider relevant material, the satisfaction recorded must have a rational nexus with that material, and the affected purchaser must receive a reasonable opportunity of hearing. The text also notes that comparative valuation and sufficiency of evidence are not to be reappraised in writ jurisdiction, and that delay in approaching the court can be fatal where the statutory timetable is tight. It further indicates that an intending purchaser may be treated as directly affected for purposes of notice and challenge.
Issues: (i) Whether the intending purchaser could maintain a writ petition challenging the acquisition order under Chapter XX-C of the Income-tax Act, 1961; (ii) Whether the order of compulsory purchase was vitiated by failure to consider relevant comparable instances or by breach of natural justice in granting opportunity before passing the order; (iii) Whether the writ petition was liable to be rejected on the ground of delay and laches.
Issue (i): Whether the intending purchaser could maintain a writ petition challenging the acquisition order under Chapter XX-C of the Income-tax Act, 1961.
Analysis: The challenge to maintainability was rejected. The petitioners had been issued the show-cause notice, their objections were heard and considered, and the authority had proceeded against them as persons directly affected by the proposed purchase. The right to be heard and to challenge the order could not be denied on the footing that the purchaser had no sufficient interest to invoke writ jurisdiction.
Conclusion: The writ petition was maintainable, and this objection was rejected.
Issue (ii): Whether the order of compulsory purchase was vitiated by failure to consider relevant comparable instances or by breach of natural justice in granting opportunity before passing the order.
Analysis: The court held that in proceedings under Chapter XX-C, judicial review is confined to whether relevant material was considered and whether the authority's satisfaction had a rational nexus with the materials before it. It was not open to reweigh the evidence or substitute the court's view on valuation. The comparable instances relied upon by the authority were not shown to be irrelevant as a matter of law. On natural justice, the Supreme Court's requirement was only of a reasonable opportunity, and the authority could conduct a brief or summary inquiry. The petitioners had notice, three hearings, and copies of the material relied upon, which was treated as sufficient compliance.
Conclusion: The acquisition order was not vitiated on either ground, and this challenge failed.
Issue (iii): Whether the writ petition was liable to be rejected on the ground of delay and laches.
Analysis: The petitioners approached the court after several weeks, by which time possession had been taken, consideration had been paid, and the property had been advertised for sale. In the tight time-frame governing Chapter XX-C, such delay was held to be fatal. The court emphasised the need for expedition on the part of affected parties as well as the authority.
Conclusion: The petition was also barred by delay and laches.
Final Conclusion: The challenge to the compulsory purchase order failed on merits and was independently defeated by the petitioners' unexplained delay, so the writ petition was dismissed.
Ratio Decidendi: In proceedings for compulsory purchase under Chapter XX-C, the court will interfere only where the authority ignores relevant material, acts without rational nexus, or denies a reasonable opportunity of hearing; the sufficiency of evidence and comparative valuation are not open to reappraisal in writ jurisdiction, and unexplained delay in invoking such relief can itself be fatal.
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