Material suppression of past agreements to waive compensation for land release precludes relief under Article 300A.

The Petitioners challenged the acquisition of 25.39 acres of land in Survey No. 210, Village Wakad, initially acquired for the Pimpri Chinchwad New Township

Following a 1970 Section 4 notification and a 1986 award, the Petitioners sought deletion of the land under Section 48 of the Land Acquisition (LA) Act

In 1992, the State released 76.17 acres but retained 25.39 acres

The Petitioners filed Writ Petition No. 1116 of 1993 to enforce this release, where they reportedly agreed to waive compensation for the retained 25.39 acres in exchange for the release of the larger portion

Possession was taken in 2000

In 2012, Petitioners filed the current petition alleging "fraud on the statute" per *Royal Orchid Hotels*, claiming the land was being leased to private parties instead of being used for a "District Commercial Centre"

In 2023, they amended the petition to claim monetary compensation under the Act of 2013

1. Whether the allotment of acquired land to private parties through 99-year leases for residential/commercial use constituted a fraud on the statute or a departure from the public purpose.

2. Whether the Petitioners are entitled to monetary compensation under the Act of 2013, specifically invoking the proviso to Section 24(2).

3. Whether the Petitioners are barred from seeking relief due to material suppression of facts and the doctrine of delay and laches.

The Court applied Section 48 of the Land Acquisition Act, 1894, regarding the withdrawal from acquisition

Section 24 of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013, concerning the lapsing or grant of fresh compensation

It relied on *Royal Orchid Hotels Ltd. v. G. Jayarama Reddy* (2011) regarding fraud on power

the Constitution Bench decision in *Indore Development Authority v. Manoharlal* (2020) which clarified that Section 24(2) cannot revive stale claims where landowners refused compensation

The court also applied the principle from *Kishore Samrite v. State of U.P.* (2013) that a litigant approaching the court with "unclean hands" by suppressing material facts is entitled to no relief

The Court found that the stated public purpose was "planned development," which inherently included industrial, commercial, and residential uses; thus, leasing plots to private entities for township development was not a "fraud"

Critically, the Court determined that the Petitioners suppressed a vital fact: in a 1993 petition, they had explicitly stated an agreement to waive compensation for the 25.39 acres in exchange for the release of 76.17 acres

This "bargain" was previously noted by the Supreme Court in *Pimpri Chinchwad New Township Dev. Authority v. Vishnudev Co-op Housing Society*

The Court rejected the Petitioners' reliance on *Vidya Devi* and *Sukh Dutt Ratra* regarding Article 300A, noting those cases involved illiterate or unaware owners, whereas the current Petitioners were sophisticated litigants who willfully handed over possession in 2000 and only sought compensation 23 years later via amendment

Application of *Indore Development Authority* confirmed that Section 24(2) cannot be used as a tool to bypass a voluntary "bargain" or to reward a litigant who refused compensation and stayed silent for decades

there was no fraud on the statute as the land use aligned with the broad "planned development" purpose

Petitioners were dis-entitled to compensation under the Act of 2013 because they had voluntarily waived it in 1992-93 and were hit by gross delay and laches

no relief could be granted to a party approaching the Court with "unclean hands"

All pending applications were disposed of accordingly