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Issues: (i) whether acquisition of lands around the Tirumala temple complex for widening roads, construction of choultries and kalyana mantapams, and implementation of the development plan was for a valid public purpose and sufficiently specific; (ii) whether the Section 5-A enquiry was vitiated by non-supply of the development plan or by alleged defects in consideration of objections; (iii) whether acquisition of properties belonging to religious denominations was barred by Article 26 of the Constitution.
Issue (i): whether acquisition of lands around the Tirumala temple complex for widening roads, construction of choultries and kalyana mantapams, and implementation of the development plan was for a valid public purpose and sufficiently specific.
Analysis: The purpose of acquisition was the orderly, integrated development of the temple area, preservation of the sanctity of the shrine, and accommodation of heavy pilgrim traffic. The Court held that a general description such as planned development or implementation of a master plan is not vague where the acquisition covers a large area and the objects are plainly connected with road widening, pilgrim amenities, and temple-town development. It was unnecessary that each plot should be tied in advance to a particular structure or that a detailed construction plan should precede acquisition.
Conclusion: The acquisition was for a valid public purpose and the description of purpose in the notifications was sufficiently specific.
Issue (ii): whether the Section 5-A enquiry was vitiated by non-supply of the development plan or by alleged defects in consideration of objections.
Analysis: The Court held that the test is whether the objectors suffered prejudice. Although one objector had sought a copy of the development plan and the enquiry should have addressed that request more appropriately, the defect did not cause such prejudice as to justify interference. The objections were substantially understood in the context of the overall acquisition scheme, and the writ jurisdiction would not be exercised merely because of an irregularity unless justice required intervention.
Conclusion: The Section 5-A enquiry was not invalidated by the alleged procedural defects.
Issue (iii): whether acquisition of properties belonging to religious denominations was barred by Article 26 of the Constitution.
Analysis: The Court held that Article 26 does not confer immunity from compulsory acquisition made in accordance with law. Acquisition would be impermissible only if it destroyed the denomination's ability to exist or to own and acquire property altogether. As the lands in question were only some of the denomination's properties, acquisition with compensation did not extinguish its constitutional rights. The fact that some properties were themselves being used for religious or charitable purposes did not prevent acquisition for another public purpose.
Conclusion: Article 26 did not bar the acquisition.
Final Conclusion: The challenge to the acquisition proceedings failed in all material respects, and the notifications and declarations were upheld.
Ratio Decidendi: Acquisition for integrated planned development and pilgrim-related civic improvements is a valid public purpose even when the exact use of each acquired plot is not predetermined, and Article 26 does not immunize religious property from compulsory acquisition made in accordance with law.