Proprietary estoppel barred insistence on market value for reconveyance after the Government accepted full payment.

A petitioner sought reconveyance of land purchased by the State in revenue recovery proceedings without paying market value, relying on the Government's acceptance of the tax liability payment and proprietary estoppel. The reconveyance policy applied only to applications made within its terms, and the payment here was not made under that policy. However, because the Government accepted the full amount after the sale without objection and there was no fraud, misrepresentation, mistake, or compulsion, the Court held that equitable proprietary estoppel prevented insistence on market value. Relief was granted and reconveyance allowed without that payment.

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Issues: Whether the petitioner was entitled to reconveyance of the bought-in land without remitting market value, on the basis of the Government's acceptance of payment towards the tax liability and the equitable doctrine of proprietary estoppel.

Analysis: The land had been purchased by the State in revenue recovery proceedings, but the petitioner later remitted the entire amount due and the Government accepted it without demur. The reconveyance policy applied to applications made within its own terms, yet the payment here was not made pursuant to that policy. There was no case of fraud, misrepresentation, mistake, or compulsion. On the facts, the Government's conduct in accepting payment after the sale and allowing the petitioner to discharge the liability gave rise to equitable considerations. The Court treated proprietary estoppel as sufficient to prevent the Government from insisting on market value in these circumstances.

Conclusion: The petitioner was entitled to reconveyance without payment of market value, and relief was granted.

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