Promissory estoppel cannot cure lack of authority: lease of nazul land without lawful transfer was held unenforceable.

Promissory estoppel cannot validate a representation or lease made without legal authority, and it cannot prevent the State from objecting where nazul land was never notified or transferred to the public body. The governing scheme required an affirmative act of vesting or transfer before the body could lease the land; mere knowledge of the auction by the State did not confer competence. As no lawful transfer to the public body was shown, the lease was ultra vires, unenforceable against the State, and the State was free to proceed in accordance with law.

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Issues: (i) Whether the State was estopped from disputing the GDA's authority to grant the lease of the nazul land on the ground that the land had not been transferred to it; (ii) Whether the lease granted by the GDA over nazul land was legally valid in the absence of a notification or other affirmative act transferring the land to the GDA.

Issue (i): Whether the State was estopped from disputing the GDA's authority to grant the lease of the nazul land on the ground that the land had not been transferred to it.

Analysis: Promissory estoppel cannot operate against a representation or promise that is prohibited by law or made without authority. The land in question remained nazul land of the State and nothing showed that it had been notified or transferred in favour of the GDA. In the absence of such transfer, the GDA could not derive authority merely from the fact that the auction was conducted with the State's knowledge.

Conclusion: The State was not estopped from raising the objection, and the plea of estoppel was rejected.

Issue (ii): Whether the lease granted by the GDA over nazul land was legally valid in the absence of a notification or other affirmative act transferring the land to the GDA.

Analysis: Under the governing statutory scheme, nazul land does not automatically vest in an authority unless affirmative steps are taken by the State by notification or transfer. Since the land continued to belong to the State and no legally effective transfer to the GDA was established, the GDA lacked competence to lease it. A grant made without authority is ultra vires and cannot confer enforceable rights on the lessee.

Conclusion: The lease was invalid and unenforceable against the State.

Final Conclusion: The impugned orders were unsustainable, the appeals were allowed, and the State was permitted to proceed in accordance with law against the lessee.

Ratio Decidendi: Estoppel cannot validate an act done without statutory authority, and a lease of government land by a public body is void when no lawful transfer or vesting of the land in that body is shown.

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