Negative equality and alleged estoppel cannot defeat acquisition where no lawful exemption or binding assurance exists.

Article 14 does not allow a claimant to demand the same benefit as another unit if the earlier exemption was erroneous or unlawful, and the court will not treat such negative equality as a ground to quash acquisition. The planned development authority's satisfaction on whether exemption would prejudice the scheme was not to be displaced by judicial substitution of view, so the discrimination challenge failed. A representation linked to change of land use and surrender of land for widening did not create an enforceable estoppel against the State, and any remedy lay elsewhere. The acquisition proceedings were therefore upheld.

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Issues: (i) whether the acquisition proceedings were liable to be quashed on the ground of discrimination and arbitrariness under Article 14 because some similarly situated units had been exempted from acquisition; (ii) whether the alleged promise connected with change of land use and surrender of land for widening of the passage created an enforceable estoppel against the State so as to bar acquisition.

Issue (i): whether the acquisition proceedings were liable to be quashed on the ground of discrimination and arbitrariness under Article 14 because some similarly situated units had been exempted from acquisition.

Analysis: The exemption granted to certain units, even if assumed to be erroneous, could not be used by the appellants to demand identical relief. Equal treatment under Article 14 presupposes a lawful and similar footing, and a wrong benefit given to one party does not create a right in another to claim the same illegality. The authority concerned with planned industrial development was entitled to assess whether exemption would impair the development scheme, and the courts would not substitute their own view for that administrative satisfaction.

Conclusion: The challenge based on discrimination and negative equality failed, and the acquisition could not be struck down on that ground.

Issue (ii): whether the alleged promise connected with change of land use and surrender of land for widening of the passage created an enforceable estoppel against the State so as to bar acquisition.

Analysis: A representation said to have been made in the process of obtaining change-of-user permission did not amount to a legally enforceable assurance preventing acquisition by the State. Even if the appellants had acted on such representation, their remedy, if any, would lie elsewhere and not in invalidating the acquisition proceedings. The existence of acquisition power under the land acquisition law remained unaffected by the alleged promise.

Conclusion: No enforceable estoppel arose against the State, and the acquisition was not vitiated on this ground.

Final Conclusion: The acquisition proceedings were upheld, and the appeals failed in entirety.

Ratio Decidendi: Article 14 does not permit a claimant to seek equality with an unlawful or erroneous concession granted to others, and an unfulfilled administrative representation does not bar acquisition unless it creates a legally enforceable estoppel.

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