In land acquisition appeals, delay may be condoned, but interest is denied for the delayed period.

The appeals under Section 54 of the Land Acquisition Act, 1894 were filed by landowners seeking enhancement of compensation awarded by the Reference Court, while the State filed connected appeals challenging the enhancement.

Some landowners had earlier approached the Collector under Section 28A of the 1894 Act after the High Court’s judgment dated 2 March 2022, although they had already sought references under Section 18; those applications were subsequently withdrawn and the appeals were filed.

The parties agreed that the appeals were covered by the High Court’s earlier decision in RFA-458-2016, dated 2 March 2022, which had assessed the market value at ₹44,62,500 per acre.

Whether the delay in filing or refiling the landowners’ appeals ought to be condoned in the circumstances of the land-acquisition proceedings?

Whether, upon condonation of delay, the landowners were entitled to statutory benefits and interest for the delayed period under the Land Acquisition Act, 1894?

Whether the market value of the acquired land was required to be enhanced to ₹44,62,500 per acre in accordance with the earlier decision in RFA-458-2016?

The Court applied Section 5 of the Limitation Act, 1963, holding that limitation provisions must be enforced in accordance with public policy, but that a liberal, justice-oriented approach may be adopted where sufficient cause is shown, particularly in land-acquisition matters; the discretion remains judicial and cannot be exercised mechanically, as explained in Pathapati Subba Reddy v. Special Deputy Collector, 2024 (12) SCC 336.

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

However, the Court applied the land-acquisition-specific approach in New Okhla Industrial Development Authority v. Rameshwar @ Ramesh Chandra Sharma, 2022 SCC OnLine SC 1599, that delay may be condoned to grant just compensation, but the acquiring body should not ordinarily be saddled with statutory benefits or interest for the delayed period.

The Court further relied on Suresh Kumar v. State of Haryana, 2025 SCC OnLine SC 896, and Urban Improvement Trust v. Vidhya Devi, 2024 SCC OnLine SC 3725, which favour adjudication on merits in land-acquisition cases and recognise the constitutional protection of property under Article 300-A.

The appeals were governed substantively by Sections 18, 28A and 54 of the Land Acquisition Act, 1894.

The Court reconciled the competing limitation principles by treating land-acquisition appeals differently from ordinary civil disputes.

Although the Supreme Court authorities require a bona fide explanation and discourage mechanical condonation of inordinate delay, the Court noted that landowners should not be denied fair compensation merely because they approached the Court late, particularly where similarly situated landowners had obtained enhanced compensation.

The Court also considered the appellants’ prior, albeit misconceived, resort to Section 28A as a relevant circumstance explaining the delay.

Accordingly, the delay was condoned.

Consistent with New Okhla Industrial Development Authority, the Court denied interest for the period attributable to the delay.

Nevertheless, because the appellants had inadvertently pursued the Section 28A remedy, the Court directed that the applicable statutory benefits would be available, while excluding interest for the delayed period.

On the merits, since both sides accepted that the cases were covered by the earlier decision in RFA-458-2016, the Court adopted the previously determined market value of ₹44,62,500 per acre.

The landowners were held entitled to compensation calculated at ₹44,62,500 per acre, in terms of the earlier judgment in RFA-458-2016.

The landowners were granted applicable statutory benefits, but no interest was payable for the delayed period.

The landowners’ appeals were allowed accordingly, the State’s appeals were dismissed, and all pending applications were disposed of.