7,581-day delay condoned in land acquisition appeals; Punjab landowners awarded parity compensation but denied interest and statutory benefits for the delayed period

The appellant challenged the award dated 31.08.2005 passed by the Additional District Judge, Gurdaspur, which allegedly did not grant the compensation claimed in respect of the acquired land.

The appeal was filed with an application seeking condonation of 7581 days’ delay.

The appellant relied on poor financial circumstances and contended that similarly situated landowners had obtained enhanced compensation in appeals allowed by the High Court.

The State conceded that the appellant’s claim was covered by the High Court’s judgment dated 02.11.2018 in RFA-1006-2010.

Three connected appeals involved common issues and were decided by the same order.

1. Whether the delay of 7581 days in filing the appeal under Section 54 of the Land Acquisition Act, 1894, should be condoned in the circumstances of the case?

2. Whether the appellant was entitled to enhanced compensation in terms of the judgment dated 02.11.2018 in RFA-1006-2010?

3. Whether the appellant could claim statutory benefits and interest for the period covered by the delay?

The Court applied Section 5 of the Limitation Act, 1963, under which delay may be condoned upon sufficient cause, while recognising that limitation provisions are based on public policy and cannot ordinarily be defeated by a merely liberal approach, as explained in Pathapati Subba Reddy (Died) by LRs v. Special Deputy Collector, 2024 (12) SCC 336.

It considered Shivamma (Dead) v. Karnataka Housing Board, 2025 SCC OnLine SC 1969, which cautions against condoning inordinate delay without a bona fide explanation.

In land-acquisition matters, however, New Okhla Industrial Development Authority v. Rameshwar, 2022 SCC OnLine SC 1599, and Suresh Kumar v. State of Haryana, 2025 SCC OnLine SC 896, establish that delay may be condoned to ensure just compensation, but interest and statutory benefits should not be awarded for the delayed period.

The Court also relied on Urban Improvement Trust v. Vidhya Devi, 2024 SCC OnLine SC 3725, which favours a justice-oriented approach where the right to property under Article 300A is implicated.

The appeal itself was maintainable under Section 54 of the Land Acquisition Act, 1894.

The Court reconciled the strict principles governing limitation with the beneficial nature of land-acquisition law.

Although the delay was exceptionally long, the appellant was a landowner claiming parity with similarly situated landowners whose appeals had already succeeded.

The State conceded both that the claim was covered by the earlier High Court judgment and that the appellant could not receive interest or statutory benefits for the delayed period.

Relying on the Supreme Court’s recognition that delay should not defeat a landowner’s entitlement to just and reasonable compensation, the Court exercised its discretion under Section 5 and condoned the delay.

At the same time, it protected the acquiring authority from the financial consequences of the appellant’s prolonged inaction by excluding interest and statutory benefits for the entire delayed period.

The connected appeals were allowed in terms of the High Court’s judgment dated 02.11.2018 in RFA-1006-2010, thereby granting the appellant the corresponding enhanced compensation.

However, the appellant was expressly held not entitled to interest for the delayed period of 7581 days or to statutory benefits.

Pending miscellaneous applications, if any, were disposed of.