Municipal and coastal permissions still govern hoardings on statutory land unless special law clearly excludes local control.

Hoardings erected on land vested in the Airports Authority of India remained subject to municipal, planning and coastal regulation because the land was outside the airport proper and the special statute did not create an express exemption. Prior permission from the municipal corporation and the competent coastal authority was required for such structures, and the local laws governing sky-signs, projections and advertisements continued to apply. The commentary further notes that a statutory corporation is not immune from local regulatory control unless the special enactment clearly excludes it, so hoardings erected without the necessary permissions were treated as unauthorized.

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Issues: (i) Whether hoardings erected on land belonging to the Airports Authority of India could be put up without permission from the Municipal Corporation of Greater Mumbai and the Maharashtra Coastal Zone Management Authority. (ii) Whether the local planning and municipal laws governing sky-signs and advertisements applied to the land in question despite the Airports Authority of India Act.

Issue (i): Whether hoardings erected on land belonging to the Airports Authority of India could be put up without permission from the Municipal Corporation of Greater Mumbai and the Maharashtra Coastal Zone Management Authority.

Analysis: The land was found to be outside the airport proper and within the municipal and coastal regulatory setting. The Airports Authority of India was treated as a statutory corporation distinct from the Union, and the land vested in it was not immune from local law. The municipal scheme regulating streets, sky-signs and advertisements, together with the hoarding policy framed under the municipal statute, required prior municipal permission for such structures. The record also showed that the site fell within the coastal regulation framework, so development activity there could not proceed without approval under the coastal regime.

Conclusion: Permission from both the Municipal Corporation of Greater Mumbai and the competent coastal authority was required.

Issue (ii): Whether the local planning and municipal laws governing sky-signs and advertisements applied to the land in question despite the Airports Authority of India Act.

Analysis: The statutory scheme of the Airports Authority of India Act did not confer a special exemption overriding the municipal and planning statutes. The provisions relied on by the advertiser under the Maharashtra Regional and Town Planning Act were held inapplicable as a shield against the municipal regulatory regime. The municipal provisions dealing with sky-signs, projections and licences were treated as regulatory measures designed to protect planned development, traffic movement, light, ventilation and public safety. The reliance placed on the Railways line of authority was distinguished because the Airports Authority of India Act did not contain a comparable overriding provision.

Conclusion: The local planning and municipal laws applied, and the hoardings could not be erected as of right on the strength of the Airports Authority of India Act alone.

Final Conclusion: The hoardings were held to be unauthorized for want of the necessary permissions and were directed to be removed, while the connected petition concerning existing licensed hoardings was allowed only to the extent that such hoardings may continue strictly in accordance with the licence and advertisement policy.

Ratio Decidendi: A statutory corporation owning land is not immune from municipal and planning control unless the special enactment expressly excludes such regulation, and hoardings or advertisements on such land require compliance with the applicable municipal and coastal permission regime when the local laws are otherwise attracted.

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