Valid Section 4(1) notification is mandatory in land acquisition; later Section 6(1) particulars cannot cure a defective start.

A valid Section 4(1) notification is a condition precedent to land acquisition, including urgent cases, and must specify the locality and required particulars with strict compliance. A mere reference to land in the schedule without adequate description does not satisfy the statutory requirement, and a serious defect in the initial notification cannot be cured by later particulars in a Section 6(1) notification. Section 17 only allows dispensation with Section 5A in urgent cases; it does not authorise omission of Section 4(1). The acquisition proceedings were therefore unsustainable because the initial notification was invalid.

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Issues: (i) Whether the notification under Section 4(1) of the Land Acquisition Act, 1894 was invalid for failure to specify the locality and for non-compliance with the mandatory requirements of the Act, and whether the defect could be cured by the later notification under Section 6(1).

Analysis: The process of acquisition must commence with a valid notification under Section 4(1), which is a condition precedent even in urgent cases. The statutory scheme requires the Government to specify the locality in which the land is needed, and a notification that merely refers to the land in the schedule without adequate particulars does not satisfy this requirement. A serious defect in the initial notification cannot be cured by supplying particulars later in a Section 6(1) notification, because the first step towards depriving a person of property must be strictly construed. Section 17 only permits the State to dispense with Section 5A in urgent cases; it does not authorise omission of Section 4(1).

Conclusion: The Section 4(1) notification was invalid, the acquisition proceedings were bad, and the defect was not cured by the Section 6(1) notification.

Final Conclusion: The appellants succeeded and the High Court's judgment was set aside, with the acquisition notifications held unsustainable.

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