Lis pendens and vesting in acquisition bar subsequent purchasers from challenging the proceedings or seeking release of the land.

A purchaser who acquires land after a Section 4 acquisition notification, and during pending litigation concerning that acquisition, takes the property subject to the result of that litigation under lis pendens and cannot claim immunity from the final adjudication. Once possession is taken, the land vests in the State free from encumbrances, so it cannot later be divested and a release or de-notification is not maintainable. On those principles, the subsequent purchasers could not challenge the acquisition, and the release order could not survive after vesting.

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Issues: (i) Whether purchasers of land after issuance of a Section 4 notification could challenge the acquisition proceedings and claim immunity from the effect of pending litigation. (ii) Whether de-notification or release of the land from acquisition was permissible after possession had been taken and the land had vested in the State.

Issue (i): Whether purchasers of land after issuance of a Section 4 notification could challenge the acquisition proceedings and claim immunity from the effect of pending litigation.

Analysis: A transferee pendente lite is bound by the outcome of the litigation under the doctrine of lis pendens. Once acquisition proceedings had been set in motion and the earlier de-notification was quashed, the original notifications under Sections 4 and 6 stood revived by operation of law. A person purchasing land during the pendency of such proceedings acquires no better title than the vendor and cannot avoid the binding effect of the final adjudication merely because no interim order had been passed.

Conclusion: The purchasers were not entitled to challenge the acquisition and were bound by the final orders in the earlier litigation.

Issue (ii): Whether de-notification or release of the land from acquisition was permissible after possession had been taken and the land had vested in the State.

Analysis: Once possession is taken under the Land Acquisition Act, the land vests in the State free from all encumbrances. After such vesting, the land cannot be divested and an application for release from acquisition is not maintainable. The earlier de-notification was also found unsustainable on merits, not merely on the ground of want of hearing. In that situation, the order directing de-notification could not validly stand.

Conclusion: De-notification or release of the land after vesting was impermissible and the ministerial order could not survive.

Final Conclusion: The challenge to the acquisition failed because the petitioners were subsequent purchasers during pending acquisition litigation and the land had already vested in the State before the impugned release order, leaving no legal basis for interference.

Ratio Decidendi: A purchaser of land after a Section 4 acquisition notification, and especially during pending litigation concerning the acquisition, takes the property subject to the result of that litigation and cannot defeat the acquisition once the land has vested in the State after possession is taken.

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