Deemed lapse of land acquisition follows non-payment of compensation where no tender or court deposit is shown.

For Section 24(2) of the 2013 land acquisition law, compensation was treated as unpaid where no tender to the landowner and no deposit in court were shown for the relevant parcels, and the pre-2013 acquisition therefore attracted deemed lapse. Objections to locus standi were rejected because the petitioners were shown through revenue records and a registered sale deed, while the alleged vesting in the Gaon Sabha was not substantiated by the record. Persons with a legally cognizable interest in the acquired land were held entitled to seek a declaration of lapse, and the writ petitions were allowed.

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Issues: (i) Whether the acquisition had lapsed under Section 24(2) of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 for non-payment of compensation. (ii) Whether the petitioners lacked locus standi as persons claiming through registered or unregistered transactions, and whether the claim in one petition could fail because the land was said to vest in the Gaon Sabha.

Issue (i): Whether the acquisition had lapsed under Section 24(2) of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 for non-payment of compensation.

Analysis: The acquisition proceedings were undisputedly initiated long before the 2013 Act came into force, and the respondents themselves admitted that compensation for the petitioners' lands had not been paid. The expression "payment" was applied in the sense of tender to the landowner, and if refused, deposit in court. On the admitted facts, neither tender nor deposit was shown in respect of the relevant land parcels.

Conclusion: The acquisition satisfied the statutory conditions for deemed lapse, and the petitioners succeeded on this issue.

Issue (ii): Whether the petitioners lacked locus standi as persons claiming through registered or unregistered transactions, and whether the claim in one petition could fail because the land was said to vest in the Gaon Sabha.

Analysis: The petitioners' vendor was shown in the revenue record, and one petitioner had obtained title through a registered sale deed. As to the allegation of vesting in the Gaon Sabha, the record did not establish the date or legal basis of vesting, and the objection was not substantiated. In the remaining matters, the documents relied upon were old transactions, and the petitioners were treated as subsequent purchasers and persons interested entitled to invoke the writ jurisdiction in the context of the acquisition dispute.

Conclusion: The objections to locus standi and ownership were rejected, and the petitioners were held entitled to seek the relief.

Final Conclusion: The acquisition in respect of the suit lands was declared to have lapsed, and the writ petitions were allowed.

Ratio Decidendi: For purposes of Section 24(2), non-payment of compensation means failure to tender compensation to the landowner or deposit it in court, and such lapse entitles persons with a legally cognizable interest in the acquired land to seek a declaration of deemed lapse.

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