Locus standi for transferees to seek deemed lapse under land acquisition law is recognised where the original acquisition is not challenged.

Subsequent purchasers, assignees, power of attorney holders and similar transferees may seek a declaration that acquisition proceedings have lapsed under Section 24(2) of the 2013 land acquisition law. The text distinguishes challenges to the original acquisition from claims for deemed lapse, noting that the latter arises from statutory extinguishment of the acquisition and removal of the resulting encumbrance. It also explains that the expressions "person interested", "land owner" and "affected family" are given a wider meaning under the 2013 Act, extending beyond the recorded owner where compensation interests or affected rights are involved. Earlier cases denying locus in acquisition challenges are treated as inapplicable. The Delhi transfer restrictions law does not defeat this entitlement.

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Issues: Whether subsequent purchasers, assignees, power of attorney holders and similar transferees have locus standi to seek a declaration that land acquisition proceedings have lapsed under Section 24(2) of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013.

Analysis: The challenge was not to the validity of the original acquisition proceedings but to a declaration of deemed lapse under Section 24(2) of the 2013 Act. The 2013 Act gives a wider meaning to the expressions "person interested", "land owner" and "affected family", extending them beyond the recorded owner to persons claiming an interest in compensation and others whose rights or livelihood are affected by acquisition. The Court held that the benefit of deemed lapse under Section 24(2) is not confined to the original owner, because once the acquisition lapses the impediment to transfer and the encumbrance created by the acquisition come to an end. The earlier decisions denying locus to subsequent purchasers in challenges to acquisition proceedings were distinguished on the ground that they dealt with attacks on the acquisition itself, not with a declaration of lapse under a later statute. The Court also noted that the respondents' interest arose in relation to land already affected by acquisition and that the Delhi Lands (Restrictions on Transfer) Act, 1972 did not alter the entitlement to seek such a declaration under the 2013 Act.

Conclusion: Subsequent purchasers and similarly situated transferees are entitled to maintain proceedings for a declaration of lapse under Section 24(2) of the 2013 Act, and the objection to their locus standi fails.

Final Conclusion: The appeals were liable to be dismissed, and the respondents were competent to pursue the lapse declaration in respect of the acquired land.

Ratio Decidendi: A person who acquires an interest in land affected by acquisition may maintain proceedings for a declaration of deemed lapse under Section 24(2) of the 2013 Act, because the right asserted is not a challenge to the original acquisition but a claim arising from the statutory extinguishment of that acquisition.

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