3755-day delay condoned in land acquisition appeal, but no interest or statutory benefits granted for delayed period

The appellant, Meena Devi, filed an appeal under Section 54 of the Land Acquisition Act, 1894, challenging the award dated 23 February 2016 of the Additional District Judge, Yamuna Nagar, whereby the claimed enhanced compensation was not granted.

The appeal was filed with a delay of 3,755 days. The appellant sought condonation on the ground that she lacked knowledge of the status of the proceedings and contended that similarly situated landowners had obtained relief from the High Court.

The State accepted that the appellant’s claim was covered by the judgment dated 24 February 2016 in RFA-3860-2014, but submitted that, in view of the delay, statutory benefits and interest could not be awarded for the delayed period.

Whether the delay of 3,755 days in filing the land-acquisition appeal should be condoned when the appellant claimed lack of knowledge of the proceedings and parity with similarly situated landowners?

Whether, after condoning the delay and granting compensation in terms of the precedent applicable to similarly situated landowners, the appellant was entitled to statutory benefits and interest for the delayed period?

Whether the appellant’s claim was covered by the judgment dated 24 February 2016 in RFA-3860-2014?

The Court applied Section 5 of the Limitation Act, 1963, under which delay may be condoned upon the establishment of sufficient cause, subject to judicial discretion and the public-policy objective of finality in litigation.

Relying on Pathapati Subba Reddy v. The Special Deputy Collector, 2024 (12) SCC 336, the Court noted that liberal construction of Section 5 cannot override the statutory scheme of limitation, and that merits alone do not justify condonation.

It also considered Shivamma (Dead) v. Karnataka Housing Board, 2025 SCC OnLine SC 1969, which cautions against condoning inordinate delay without sufficient cause.

However, in land-acquisition matters, the Court relied on New Okhla Industrial Development Authority v. Rameshwar, 2022 SCC OnLine SC 1599, Suresh Kumar v. State of Haryana, 2025 SCC OnLine SC 896, and Urban Improvement Trust v. Vidhya Devi, 2024 SCC OnLine SC 3725, for the principles that land losers should ordinarily receive just and fair compensation, delay may be liberally condoned in appropriate cases, and statutory benefits and interest should not be imposed on the acquiring body for the period attributable to the delayed litigation.

The Court further applied Article 300A of the Constitution, protecting the right to property and requiring fair compensation where property is acquired by the State.

The Court treated the matter as a land-acquisition case involving the appellant’s claim to compensation at parity with similarly situated landowners whose appeals had been allowed.

Although the delay of 3,755 days was exceptionally long, the Court distinguished the general approach applicable to ordinary limitation cases and adopted the more liberal approach recognized in land-acquisition jurisprudence, particularly where denial of parity would result in unequal compensation for similarly placed landowners.

Since the State conceded that the appellant’s claim was covered by the earlier judgment in RFA-3860-2014, the Court found sufficient basis to condone the delay and decide the appeal on merits.

At the same time, balancing the appellant’s entitlement to enhanced compensation against the prejudice to the acquiring authority, the Court excluded interest and statutory benefits for the entire delayed period of 3,755 days, consistently with the Supreme Court’s ruling in New Okhla Industrial Development Authority.

It thereafter allowed the appeal in terms of the judgment dated 24 February 2016 in RFA-3860-2014, thereby granting the appellant the compensation applicable under that precedent.

However, the appellant was expressly held not entitled to interest for the delayed period of 3,755 days or to statutory benefits.

Pending miscellaneous applications, if any, were disposed of.