Post-notification land purchase cannot support challenge to acquisition or claim lapse under Section 24(2) of the 2013 Act.

A purchaser acquiring land after issuance of a Section 4 notification under the Land Acquisition Act, 1894 has no title, right or interest enforceable against the State and cannot be treated as a landowner, affected family or person interested for purposes of Section 24(2) of the 2013 Act. The statutory scheme protects recorded owners and other legally entitled persons, not a transferee under a void post-notification transaction. A purchase through agreement to sell, power of attorney or will likewise does not create enforceable title for this purpose. A post-notification purchaser therefore cannot challenge the acquisition or claim lapse under Section 24(2).

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Issues: Whether a purchaser who acquired land after issuance of a Section 4 notification under the Land Acquisition Act, 1894 can challenge the acquisition or seek a declaration of lapse under Section 24(2) of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013.

Analysis: The purchase made after the Section 4 notification was void against the State and conferred no title, right, or interest in the land. A subsequent purchaser does not become a landowner, affected family, or person interested for the purpose of invoking Section 24 of the 2013 Act. The statutory scheme of the 2013 Act, including Section 11(4) and the definitions of landowner, affected family, and person interested, protects recorded owners and affected persons, not intermeddlers who purchase during acquisition. Section 24(2) operates only where the statutory conditions are satisfied by persons legally entitled to claim under the acquisition regime; it cannot be used to revive rights arising from a void transfer or to question possession taken under the 1894 Act. A transaction through power of attorney, agreement to sell, or will also does not create enforceable title for this purpose.

Conclusion: A purchaser after the Section 4 notification cannot maintain a challenge to the acquisition or claim lapse under Section 24(2); the claim fails.

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