Delay in land acquisition appeals may be condoned, but statutory benefits and interest are denied for the delayed period.

The appellants filed an appeal under Section 54 of the Land Acquisition Act, 1894, challenging the award dated 11 May 2011 passed by the Additional District Judge, Jhajjar, whereby the claimed enhancement in compensation was not awarded.

The appeal was filed with a delay of 5,381 days. The appellants sought condonation on the ground that they lacked knowledge of the status of the proceedings and relied on appeals filed by similarly situated landowners, which had been allowed by the High Court.

The State conceded that the appellants’ claim was covered by the High Court’s order dated 5 October 2021 in RFA-5620-2013, but contended that, in view of the substantial delay, the appellants could not receive statutory benefits or interest for the delayed period.

1. Whether the delay of 5,381 days in filing the appeal should be condoned in a land-acquisition matter where the appellants’ claim was covered by relief granted to similarly situated landowners.

2. Whether, upon condonation of delay and grant of enhanced compensation, the appellants were entitled to statutory benefits and interest for the period of delay.

The Court applied Section 5 of the Limitation Act, 1963, under which delay may be condoned only upon sufficient cause, while recognising that the provision should receive a liberal, justice-oriented construction, subject to the public-policy objectives of limitation law.

Relying on Pathapati Subba Reddy v. The Special Deputy Collector, 2024 (12) SCC 336, the Court noted that delay cannot be condoned mechanically; inordinate delay, negligence and lack of due diligence remain relevant, and the mere fact that similarly situated persons obtained relief does not by itself entitle a delayed litigant to the same benefit.

Shivamma (Dead) v. Karnataka Housing Board, 2025 SCC OnLine SC 1969, was relied upon for the principle that sufficient cause must be shown for the entire period of delay and that massive delay cannot ordinarily be justified by administrative lethargy or inaction.

However, the Court applied the liberal approach recognised in land-acquisition cases in 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, under which delayed landowners may be granted just compensation, but the acquiring body should not be burdened with statutory benefits or interest for the delayed period.

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

The Court balanced the strict requirements of limitation against the beneficial character of land-acquisition jurisprudence and the appellants’ entitlement to parity with similarly situated landowners. Although the delay was exceptionally long, the State accepted that the appellants’ claim was covered by the earlier decision in RFA-5620-2013, and the Court therefore adopted the liberal approach approved by the Supreme Court for land losers.

At the same time, the Court protected the acquiring authority from the financial consequences of the appellants’ prolonged inaction by excluding interest for the entire delayed period and denying statutory benefits, consistently with New Okhla Industrial Development Authority and the other cited precedents.

The main appeal was allowed in terms of the High Court’s order dated 5 October 2021 in RFA-5620-2013, thereby granting the appellants the relief applicable under that decision.

However, the appellants were expressly held not entitled to interest for the delayed period of 5,381 days or to statutory benefits.

Pending miscellaneous applications, if any, were disposed of.