Interim protection in land allotment disputes may continue where arbitrariness is plausible and final relief risks being frustrated.

Interim protection was considered under the settled tests of prima facie case, balance of convenience and irreparable injury in a writ challenge to land allotment. The Court noted material suggesting rejection of the appellant's application without reasons, unusual haste in the rival allotment, and a statutory framework requiring fair, reasoned and non-arbitrary action. It also treated the limited development of the land as relevant because refusal of protection could make the writ petition ineffective. Delay in approaching the Court was not decisive where arbitrariness and possible equality concerns were plausibly shown, and status quo was continued pending final disposal.

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Issues: Whether the appellant was entitled to interim protection pending disposal of the writ petition challenging the allotment of land, in view of the alleged arbitrariness, haste and discriminatory treatment in the allotment process.

Analysis: The interim relief question was examined against the settled principles governing temporary injunction, namely prima facie case, balance of convenience and irreparable injury. The Court found that the appellant had placed material indicating that its application had been rejected without reasons, that the allotment in favour of the other allottee had been processed with unusual haste, and that the statutory framework and the land-disposal regulations required fair, reasoned and non-arbitrary action. The circumstances also suggested that the disputed land had not substantially been developed, so refusal of interim protection could render the writ petition ineffective. Although there had been delay in approaching the Court, the delay was not treated as decisive in the face of a plausible case of arbitrariness and possible violation of equality principles.

Conclusion: Interim protection was warranted and the appellant succeeded on the request for interim relief.

Final Conclusion: The Court held that the writ petitioner should be protected till the writ petition is decided by the High Court, and the status quo order was directed to continue pending final disposal of the writ proceedings.

Ratio Decidendi: Interim relief may be granted even at a belated stage where the impugned State action appears arbitrary or discriminatory, the applicant shows a prima facie case, and denial of protection would risk irretrievable consequences before final adjudication.

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