Retrospective validation of coal-bearing land acquisition defeated the challenge based on absence of a Section 7 notification.

The Coal Bearing Areas (Acquisition and Development) Act, 1957 was applied with retrospective validating effect through the 1969 Amendment Act. Notifications under Section 4(1) of the Land Acquisition Act, 1894 and objections under Section 5A were treated as corresponding steps under the 1957 Act by Section 28, while the amendment deemed a Section 7 notification to exist where no Section 5A objection had been filed. Section 3 further validated acquisitions notwithstanding any court judgment, decree or order. The amendment removed the basis for judicial interference, and the acquisition was upheld as valid despite the absence of a separate Section 7 notification.

---

---

Issues: Whether the acquisition of land could be invalidated for want of a notification under Section 7 of the Coal Bearing Areas (Acquisition and Development) Act, 1957, in view of the retrospective amendments made by the Coal Bearing Areas (Acquisition and Development) Amendment Act, 1969.

Analysis: The statutory scheme treated earlier notifications under Section 4(1) of the Land Acquisition Act, 1894 and objections under Section 5A of that Act as notifications and objections under the Coal Bearing Areas (Acquisition and Development) Act, 1957 by force of Section 28. The amending Act of 1969 further introduced a deeming provision that where no objection had been filed under Section 5A, a notification under Section 7 would be deemed to exist, and Section 3 expressly validated the acquisitions notwithstanding any judgment, decree, or order of any court. The effect of the amendment was to remove the basis on which the High Court had interfered.

Conclusion: The acquisition was held to be valid and the challenge based on absence of a Section 7 notification failed.

---