Delayed land acquisition appeals may be condoned, but statutory benefits and interest are barred for the delayed period.

The appellants, who were landowners affected by compulsory acquisition, challenged the award dated 25.10.2012 passed by the Additional District Judge, Karnal, which did not grant the compensation claimed by them.

They filed appeals under Section 54 of the Land Acquisition Act, 1894, accompanied by applications seeking condonation of a delay of 4,858 days.

The appellants pleaded that they lacked knowledge of the status of the proceedings and contended that similarly situated landowners had obtained relief from the High Court; therefore, they claimed entitlement to compensation on parity.

The State conceded that the appellants’ claim was covered by the High Court’s order dated 16.03.2026 in RFA-5681-2012, but submitted that the appellants could not receive statutory benefits or interest for the delayed period.

Whether the delay of 4,858 days in filing the appeals under Section 54 of the Land Acquisition Act, 1894, ought to be condoned in the circumstances of the case.

Whether, after condonation of delay, the appellants were entitled to compensation in terms of the judgment applicable to similarly situated landowners.

Whether the appellants were entitled to statutory benefits and interest for the period of delay in filing the appeals.

The Court applied Section 5 of the Limitation Act, 1963, under which delay may be condoned where sufficient cause is shown, while recognising that limitation law serves the public policy of bringing litigation to an end and that condonation remains discretionary, particularly in cases of inordinate delay, negligence or want of due diligence, as explained in Pathapati Subba Reddy (Died) by LRs v. The Special Deputy Collector, 2024 (12) SCC 336.

It also relied on Shivamma (Dead) v. Karnataka Housing Board, 2025 SCC OnLine SC 1969, which cautions against mechanically condoning extraordinary delays without sufficient cause throughout the entire period.

In the context of land acquisition, however, New Okhla Industrial Development Authority v. Rameshwar @ Ramesh Chandra Sharma (Dead) through LRs, 2022 SCC OnLine SC 1599, and Suresh Kumar v. State of Haryana, 2025 SCC OnLine SC 896, recognise a liberal, justice-oriented approach to protecting just compensation for landowners, while denying statutory benefits and interest for the delayed period.

The Court also relied on Urban Improvement Trust v. Vidhya Devi, 2024 SCC OnLine SC 3725, which emphasises that delay should not defeat adjudication of landowners’ property claims where Article 300-A considerations and substantial justice are involved.

The appeals themselves were governed by Section 54 of the Land Acquisition Act, 1894.

The Court balanced the strict principles governing limitation against the special considerations applicable to land acquisition matters.

Although the delay of 4,858 days was exceptionally long, the appellants’ claim was admittedly covered by the High Court’s earlier decision concerning similarly situated landowners, and the State did not dispute the merits of the claim.

Following the Supreme Court’s land-acquisition precedents, the Court held that delay should not prevent landowners from receiving compensation corresponding to the legally determined market value.

At the same time, to avoid imposing an unfair financial burden on the acquiring authority and consistently with New Okhla Industrial Development Authority and Suresh Kumar, the appellants’ entitlement was restricted by excluding statutory benefits and interest for the delayed period.

The appeals were allowed in terms of the High Court’s order dated 16.03.2026 in RFA-5681-2012.

The appellants were consequently granted the compensation relief applicable under that order, but were expressly held not entitled to interest for the delayed period of 4,858 days or to statutory benefits.

Pending miscellaneous applications were disposed of.