In land-acquisition appeals, inordinate delay may be condoned, but no interest or statutory benefits accrue for the delayed period.

The appellant challenged an award dated 30 July 2005 passed by the Additional District Judge, Gurdaspur, whereby the claimed enhancement in compensation for acquired land was not granted.

The appeals under Section 54 of the Land Acquisition Act, 1894, were filed with a delay of 5,628 days, and applications were moved for condonation of that delay.

The appellant pleaded lack of knowledge regarding the status of the case and relied upon judgments granting enhanced compensation to similarly situated landowners.

The State conceded that the appellant’s claim was covered by the High Court’s judgment dated 2 November 2018 in RFA-1006-2010, but contended that interest and statutory benefits could not be granted for the delayed period.

Whether the delay of 5,628 days in filing the appeals under Section 54 of the Land Acquisition Act, 1894, should be condoned in a land-acquisition matter where similarly situated landowners had obtained enhanced compensation?

Whether, upon condonation of the delay and grant of enhanced compensation at par with similarly situated landowners, the appellant was entitled to interest and statutory benefits for the delayed period?

The Court applied Section 5 of the Limitation Act, 1963, under which delay may be condoned upon sufficient cause, while recognising that limitation law is founded on public policy and that condonation remains discretionary: Pathapati Subba Reddy (Died) by L.Rs. v. The Special Deputy Collector, 2024 (12) SCC 336, held that a liberal approach under Section 5 cannot override the statutory scheme, and that the merits of the appeal ordinarily should not determine condonation.

Shivamma (Dead) v. Karnataka Housing Board, 2025 SCC OnLine SC 1969, emphasised that inordinate delay requires a bona fide explanation covering the entire period and should not be condoned mechanically.

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

Urban Improvement Trust v. Vidhya Devi, 2024 SCC OnLine SC 3725, further required a liberal, justice-oriented approach in land-acquisition matters, particularly in view of the constitutional protection of property under Article 300-A.

The Court treated the appeals as land-acquisition matters requiring a more liberal approach than ordinary limitation disputes.

Although the delay of 5,628 days was exceptionally long and the general principles governing inordinate delay required caution, the appellant’s entitlement to enhanced compensation was undisputedly covered by the High Court’s earlier decision in RFA-1006-2010, and the State conceded the applicability of that decision.

Balancing the appellant’s constitutional and substantive entitlement to fair compensation against the public authority’s prejudice arising from the prolonged delay, the Court condoned the delay but adopted the safeguard recognised in New Okhla Industrial Development Authority and Suresh Kumar: the acquiring body would not be burdened with interest or statutory benefits accruing during the delayed period.

The appeals were allowed in terms of the High Court’s judgment dated 2 November 2018 in RFA-1006-2010.

The appellant was granted the corresponding enhanced compensation but was expressly denied interest for the delayed period of 5,628 days and all statutory benefits.

Pending miscellaneous applications were also disposed of.