Master plan land-use entries do not confer title, and excluded plots revert to the original development area.

Land excluded from the Dayalbagh Town Area was held to revert to the Agra Development Area because the regulated-area boundaries were linked to the Town Area limits and the later exclusion notification operated as supplementary to the earlier regime. The non obstante clause did not preserve Dayalbagh control over plots no longer within the Town Area, and no fresh notification was required for the planning regime to apply. The entry showing University use in the Dayalbagh Master Plan created no enforceable title, possession right, or construction right, since a master plan regulates land use but does not transfer ownership. Promissory estoppel also failed because no clear State promise or detrimental reliance was shown.

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Issues: (i) Whether the plots, after being excised from the Dayalbagh Town Area, continued to remain within the Dayalbagh Regulated Area or reverted to the Agra Development Area. (ii) Whether the land use shown as University in the Dayalbagh Master Plan conferred any enforceable right or title on the petitioner, and whether promissory estoppel could be invoked.

Issue (i): Whether the plots, after being excised from the Dayalbagh Town Area, continued to remain within the Dayalbagh Regulated Area or reverted to the Agra Development Area.

Analysis: The boundaries of the regulated area were linked to the limits of the Town Area, and the later notification excluding the plots from the Town Area was treated as supplemental to the earlier regulated-area notification. The provisions of the relevant enactments were held to be complementary rather than inconsistent, so the non obstante clause did not preserve Dayalbagh control over land that had been taken out of the Town Area. Once excluded, the plots reverted to their original position in the Agra Development Area, and no fresh notification was necessary for their treatment under that area's planning regime.

Conclusion: The plots ceased to be subject to the Dayalbagh Regulated Area and fell within the jurisdiction of the Agra Development Area.

Issue (ii): Whether the land use shown as University in the Dayalbagh Master Plan conferred any enforceable right or title on the petitioner, and whether promissory estoppel could be invoked.

Analysis: A master plan regulates land use and development, but it does not determine ownership or transfer title. The fact that land is shown for a particular use does not by itself vest any proprietary right in the person who may benefit from that use. The petitioner had no title to the plots and no acquisition or conveyance in its favour was shown. The doctrine of promissory estoppel also failed because no clear and unequivocal promise by the State, or alteration of position founded upon such promise, was established.

Conclusion: The petitioner acquired no right to possession or construction merely from the land-use entry in the Dayalbagh Master Plan, and promissory estoppel was not made out.

Final Conclusion: The planning control over the disputed plots belonged to the Agra Development Area, and the petitioner could not challenge the sanctioned construction merely on the basis of the Dayalbagh land-use entry.

Ratio Decidendi: A master plan governs permissible land use but does not confer title, and where land is excluded from a regulated area by a later notification linked to the town-area boundary, jurisdiction reverts to the original development area unless a contrary legal basis is shown.

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