Proposal for land reconveyance must be decided on merits where acquired land remains unutilized by the beneficiary.

The appellant, CS Jain Educational Trust, filed an intra-Court appeal against an order dated 01.04.2026 in W.P.No.36619 of 2024

The dispute concerns land originally acquired for a power plant project by the Tamil Nadu Industrial Captive Power Corp. Ltd. (Respondent No. 4).

A report by the District Revenue Officer, Cuddalore, noted that during an enquiry on 12.12.2025, the power plant company failed to participate

Finding that the project had not commenced, the District Collector forwarded a proposal on 26.12.2025 to the Commissionerate of Land Administration recommending the re-conveyance of the acquired land to the appellant

1. Whether the proposal for re-conveyance of acquired land, initiated by the District Collector due to non-utilization by the beneficiary company, should be finalized by the competent authority

The court applied the administrative principle of "merit-based adjudication" and the statutory framework governing land acquisition and re-conveyance in Tamil Nadu (impliedly the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013, or relevant State Revenue Standing Orders regarding non-utilization of acquired land).

The rule dictates that where acquired land remains unutilized for its intended public purpose, the government may consider re-conveying it to the original owner or petitioner upon proper enquiry and proposal by revenue officials

The Court examined the procedural history and the findings of the revenue officials. It noted that the District Revenue Officer's report and the Sub-Collector’s findings established a lack of progress by the 4th Respondent on the subject land

The Court reasoned that since the District Collector had already exercised his discretion to forward a formal proposal for re-conveyance to the Commissionerate of Land Administration (CLA) on 26.12.2025, the appropriate legal course was to mandate the CLA to take a final decision.

The court emphasized that this decision must be made "on merits and in accordance with law" to resolve the "longstanding issues" between the Trust and the Government

The Court held that a final decision must be taken as expeditiously as possible to resolve the dispute.

Consequently, the impugned order in the Writ Petition was modified by these directions, and the connected miscellaneous petition was closed with no order as to costs