Vacant land under urban ceiling law can be judged by a later lawful master plan, not only the plan at commencement.

Under the Urban Land (Ceiling & Regulations) Act, 1976, whether land is vacant land depends on the statutory definitions and the land's character at the relevant time, and the Act's broad definition of "master plan" extends to plans prepared under any law in force. A master plan lawfully prepared after the Act commenced may therefore be taken into account when determining vacancy, because the scheme does not freeze development control to the position existing on 17 February 1976 and contemplates later lawful planning changes. The earlier contrary view was held not to state the law correctly.

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Issues: Whether, for determining if land is vacant land under the Urban Land (Ceiling & Regulations) Act, 1976, the relevant master plan is only the one in force when the Act commenced or also a master plan prepared subsequently under the law in force.

Analysis: The definition of "urban land" and "vacant land" in the Act turns on the master plan and the state of the land at the relevant time. The Act also defines "master plan" broadly as a plan prepared under any law for the time being in force, which shows that the statutory scheme does not freeze development control to the position existing on 17 February 1976. The explanation to Section 6(1) recognizes that land may become vacant land later by reason of events occurring after the Act commenced, and the filing obligations under Sections 6, 15 and 16 may arise when land acquires the character of vacant land. Development and town planning are continuing processes, and the statute contemplates later lawful planning changes.

Conclusion: A master plan prepared in accordance with law even after the commencement of the Act can be taken into account to determine whether land is vacant land. The earlier contrary view was held not to state the law correctly.

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