Acquisition finality and vesting preclude land restoration despite non-use or subsequent project site relocation.

The appellants owned agricultural land in Anuppur, which was acquired by the State under the Land Acquisition Act, 1894, for a District Hospital

During proceedings, the authorities held a meeting on 20.05.2008 and agreed "in principle" to allot alternative land in exchange for the acquired land

However, an award determined monetary compensation on 06.12.2008, and the request for exchange was formally rejected on 13.04.2010

The appellants filed W.P. No. 11973/2014, arguing that the hospital was built elsewhere and the acquired land remained unused

The learned Single Judge dismissed the petition on 23.04.2026, leading to this writ appeal

1. Whether the acquisition proceedings lapsed under Section 24(2) of the 2013 Act due to the appellants’ non-acceptance of compensation.

2. Whether the "in principle" agreement for land exchange in the Minutes of Meeting dated 20.05.2008 created an enforceable legal right.

3. Whether the non-utilization of the acquired land for the specific intended purpose (District Hospital) entitles the appellants to restoration or reconveyance of the land.

Section 16 of the Land Acquisition Act, 1894, which dictates that land vests absolutely in the State free from all encumbrances once an award is made and possession is taken

Constitution Bench precedent in Indore Development Authority v. Manoharlal (2020) 8 SCC 129, which clarified that acquisition does not lapse under Section 24(2) of the 2013 Act if the State has tendered compensation, even if the landowner refuses to accept it

Principles of administrative law regarding "enforceable rights," noting that internal correspondences and "in principle" proposals do not constitute binding contracts or statutory rights

The court reasoned that the acquisition reached finality upon the passing of the award on 06.12.2008, at which point the land vested in the State under Section 16

Applying Indore Development Authority, the court held that the appellants' choice to decline the deposited compensation did not invalidate the concluded proceedings

Regarding the promise of alternative land, the court observed that the 2008 Minutes and 2016-2017 correspondences were merely administrative proposals that never culminated in a final order by a competent authority; thus, there was no vested right to an exchange

Finally, the court rejected the plea for restoration based on non-utilization, concluding that once land vests in the State, the original owner loses all proprietary interest, and a subsequent change in the project's location does not create a right to reconveyance

It held that the acquisition was lawful and final, and the appellants were not entitled to the restoration of land or a mandatory exchange

The court concluded that the 2013 Act had no retrospective application to this concluded case and the doctrine of Promissory Estoppel did not apply in the absence of a statutory decision

No order as to costs was made