Property transfer post-acquisition and receipt of compensation is void and confers no title on subsequent purchasers.

The Appellants (legal heirs of Late Smt. Raj Kumari) challenged an order dated 03.02.2026 which dismissed their Writ Petition seeking to restrain the Delhi Development Authority (DDA) from taking possession of a property in Prahladpur Bangar

The property was subject to acquisition under the Land Acquisition Act, 1894, which culminated in an award in 2002

Although the Appellants claimed the property was purchased via Agreement to Sell and Power of Attorney between 2015-2016, the original owner (predecessor-in-interest) had already received compensation for the acquisition

The Appellants contended that since the area was notified for "in-situ development" and regularization as an unplanned industrial area under the Master Plan for Delhi-2021, possession could not be taken

1. Whether a purchase of land subsequent to its valid acquisition and the passing of an award grants the purchaser any legal right or title

2. Whether the notifications regarding regularization of unauthorized colonies/industrial areas negate a prior completed land acquisition under the 1894 Act

Section 3 of the Delhi Lands (Restriction on Transfer) Act, 1972, which prohibits the transfer of any land in Delhi that has been acquired by the Central Government under the Land Acquisition Act, 1894

Shiv Kumar v. Union of India (2019) and Premji Ratansey Shah v. Union of India (1994), which establish that once land is acquired, any subsequent sale is void and the purchaser is at best an encroacher with no standing to challenge the acquisition

National Capital Territory of Delhi (Recognition of Property Rights of Residents in Unauthorized Colonies) Act, 2019 regarding the recognition of ownership rights

The Court reasoned that because the property had been validly acquired and the award passed in 2002—with compensation paid to the original owners—any subsequent "sale" to Smt. Raj Kumari in 2015-2016 was a nullity

Under Section 3 of the Delhi Lands (Restriction on Transfer) Act, 1972, such transfers are expressly prohibited and "void"

Consequently, the Appellants could not claim the protection of the 2019 Act or Master Plan notifications because those provisions do not validate illegal transfers of government-acquired land

The Court found that notifications for "in-situ development" do not divest the DDA of its lawful title obtained through a finalized acquisition process

The Court dismissed the appeal and affirmed the Single Judge's order... The Court noted that the Appellants' only potential remedy lies in seeking relief against their predecessor-in-title for fraudulently transferring property that had already been acquired and compensated for. All pending applications were dismissed.