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Issues: Whether the acquisition proceedings could be held to have lapsed under Section 24(2) of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 where the award had been made long before commencement of the Act, possession was disputed, and compensation had been deposited with the Land Acquisition Collector.
Analysis: The matter involved competing views on the meaning of "compensation has not been paid" in Section 24(2), the effect of deposit under Section 31 of the Land Acquisition Act, 1894, the consequence of non-deposit in the Reference Court, and whether refusal by landowners to receive compensation could still attract lapse of proceedings. The Court noted that these questions raised larger implications and that several related issues had not been considered in the earlier decisions relied upon by the High Court.
Conclusion: The Court did not finally decide the Section 24(2) lapse issue on merits and held that the matter should be placed before the Chief Justice of India for appropriate orders on reference to a larger Bench.
Final Conclusion: The judgment left the substantive controversy unresolved at this stage and directed that the case be considered by a larger Bench.
Ratio Decidendi: Where the meaning and effect of Section 24(2) of the 2013 Act involved unresolved questions not fully addressed in prior decisions, the proper course was reference to a larger Bench rather than final determination on merits.
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