In land-acquisition appeals, inordinate delay by landowners may be condoned, but delayed-period interest and statutory benefits remain unavailable.

The appellants sought condonation of a delay of 3,653 days in filing an appeal under Section 54 of the Land Acquisition Act, 1894.

They explained the delay on the ground that they were unable to file the appeal along with similarly situated landowners, whose appeals had allegedly been allowed and who had received compensation at parity with other landowners.

The State conceded that the claim was covered by the relevant precedent but contended that, in view of the inordinate delay, the appellants could not claim statutory benefits or interest for the delayed period.

On the merits, the appeal challenged the Additional District Judge, Rohtak’s award dated 04.03.2014, which had not granted the enhanced compensation claimed by the appellants.

The parties agreed that the matter was governed by the Court’s order dated 01.05.2025 in Murti Devi v. State of Haryana, involving land acquired under the same notification.

1. Whether the delay of 3,653 days in filing the land-acquisition appeal should be condoned in the interests of substantial justice, notwithstanding the absence of a detailed explanation covering the entire period of delay.

2. Whether, after condonation of delay, the appellants were entitled to setting aside of the award dated 04.03.2014 and enhancement of compensation when the issue was governed by the decision in Murti Devi v. State of Haryana.

3. Whether statutory benefits and interest could be awarded for the period attributable to the delayed filing of the appeal.

Section 5 of the Limitation Act, 1963 permits condonation of delay only upon establishment of sufficient cause, while Section 3 reflects the public policy that litigation must attain finality; the discretion under Section 5 must be exercised judiciously and cannot be used to defeat the statutory limitation scheme.

In Pathapati Subba Reddy v. The Special Deputy Collector, 2024 (12) SCC 336, the Supreme Court held that mere success of similarly situated persons does not by itself justify condonation, particularly where there is inordinate delay, negligence or lack of due diligence.

Shivamma (Dead) v. Karnataka Housing Board, 2025 SCC OnLine SC 1969, cautions against mechanically condoning prolonged delay caused by administrative lethargy or negligence.

However, in land-acquisition matters, New Okhla Industrial Development Authority v. Rameshwar, 2022 SCC OnLine SC 1599, and Suresh Kumar v. State of Haryana, 2025 SCC OnLine SC 896, recognise that delay may be condoned to ensure just and uniform compensation, while denying statutory benefits and interest for the delayed period.

Urban Improvement Trust v. Vidhya Devi, 2024 SCC OnLine SC 3725, further supports a liberal, justice-oriented approach in land-acquisition cases involving the constitutional right to property under Article 300-A.

Under Section 54 of the Land Acquisition Act, 1894, an aggrieved landowner may appeal against the award of the reference court.

The Court acknowledged the general rule that a litigant must satisfactorily explain the entire period of delay and that merits ordinarily should not be examined while deciding limitation.

Nevertheless, it treated land-acquisition claims differently because landowners seek fair compensation for property compulsorily acquired by the State.

Relying on the Supreme Court’s land-acquisition precedents, the Court held that a liberal approach was warranted and that delay, irrespective of its length, should be condoned where parity with similarly situated landowners and just compensation were involved.

The Court also accepted that the appellants could not claim statutory benefits or interest for the period of delay, consistent with the Supreme Court’s direction in New Okhla Industrial Development Authority and related cases.

Once delay was condoned, however, the substantive appeal was controlled by the binding order in Murti Devi, under which the market value determined by the Collector had been upheld for land acquired under the same notification.

Since the State conceded the applicability of that decision and the appellants could not distinguish it, no ground remained for interference with the award.

It held that the appellants’ land-acquisition claim warranted a liberal approach to limitation, but the benefit of statutory compensation components and interest for the delayed period was not available.

On the merits, the Court dismissed RFA-921-2026 (O&M) in terms of its order dated 01.05.2025 in Murti Devi, thereby declining to interfere with the award dated 04.03.2014.

Pending miscellaneous applications, if any, were disposed of.