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Issues: Whether the acquisition proceedings had lapsed under Section 11A of the Land Acquisition Act, 1894 because no award was made within the prescribed period, and whether the earlier writ petitions and the urgency notifications under Section 17 prevented the appellants from claiming that lapse.
Analysis: Section 11A requires the Collector to make an award within two years from the declaration, failing which the acquisition lapses, subject only to exclusion of the period during which proceedings are stayed by a court order. The earlier writ petitions filed in 1982 had ended in dismissal and the interim protection had ceased, so there was no subsisting restraint on making the award. The record showed that the respondents knew of the dismissals well before 2000, yet they did not pass an award within the statutory period. The reliance on earlier cases concerning vesting after timely possession was misplaced because, on the facts here, possession had not been taken within the statutory period and the land had not vested in the State in the manner contended.
Conclusion: The acquisition proceedings were liable to be treated as having lapsed under Section 11A, and the appellants were entitled to relief.