Land acquisition lapse from prolonged inaction and no possession; subsequent purchaser could challenge abandoned proceedings.

Land acquisition proceedings may lapse where the authority issues a final notification but then leaves the acquisition incomplete for an unreasonably long period without passing an award or taking possession. Continued inaction in such circumstances is arbitrary, and the acquisition can be treated as abandoned by efflux of time. A subsequent purchaser is not barred from challenging the acquisition where the original owner has effectively regained the right to deal with the property. The protection of property under Article 300A also requires just compensation within a reasonable time. The writ petitions were therefore maintainable and succeeded.

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Issues: Whether land acquisition proceedings, where no award was passed and possession was not taken for about three decades after the final notification, had lapsed and stood abandoned, and whether a subsequent purchaser could seek such declaration.

Analysis: The acquisition remained incomplete for an unduly long period, despite the final notification having been issued decades earlier. No award had been passed, possession had not been taken, and the land had remained with the owners, who later sold it after waiting for years. The Court held that the authority vested with acquisition power must exercise it within a reasonable period, and that prolonged inaction made continuation of the acquisition arbitrary. It further held that once the acquisition had effectively been abandoned by efflux of time, the bar against a subsequent purchaser challenging acquisition did not apply, because the original owner had regained the right to deal with the property and the purchaser could protect that interest. The Court also noted that the constitutional protection of property under Article 300A includes a right to just compensation within a reasonable time.

Conclusion: The acquisition proceedings had lapsed and stood abandoned, and the writ petitions were maintainable and succeeded.

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