Punjab and Haryana High Court condones 3,416-day delay in land acquisition appeal, grants enhanced compensation but denies delayed-period interest and statutory benefits

The appellant, a landowner affected by compulsory acquisition, challenged the award dated 14.08.2014 passed by the Additional District Judge, Rohtak, which did not grant the compensation claimed by him.

He filed the appeal under Section 54 of the Land Acquisition Act, 1894, with a delay of 3,416 days, explaining that he lacked knowledge of the status of the proceedings and that similarly situated landowners had obtained enhanced compensation in connected matters.

The State conceded that the appellant’s claim was covered by the judgment dated 29.03.2022 in RFA-9727-2014, but submitted that, in view of the delay, statutory benefits and interest for the delayed period could not be granted.

Whether the delay of 3,416 days in filing the appeal should be condoned in a land-acquisition matter where similarly situated landowners had obtained relief.

Whether the appellant was entitled to enhanced compensation in terms of the judgment in RFA-9727-2014.

Whether the appellant was entitled to statutory benefits and interest for the period of delay.

The Court applied Section 5 of the Limitation Act, 1963, under which delay may be condoned on showing sufficient cause, while recognising that limitation provisions serve the public policy of finality in litigation.

It relied on Pathapati Subba Reddy v. The Special Deputy Collector, 2024 (12) SCC 336, for the principles that condonation is discretionary, that mere parity with other litigants does not by itself establish entitlement, and that merits ordinarily should not determine an application for condonation.

It considered Shivamma (Dead) v. Karnataka Housing Board, 2025 SCC OnLine SC 1969, on the need for a bona fide explanation covering the entire period of delay.

It further relied on New Okhla Industrial Development Authority v. Rameshwar @ Ramesh Chandra Sharma, 2022 SCC OnLine SC 1599, Suresh Kumar v. State of Haryana, 2025 SCC OnLine SC 896, and Urban Improvement Trust v. Vidhya Devi, 2024 SCC OnLine SC 3725, which support a liberal, justice-oriented approach in land-acquisition cases but restrict the award of statutory benefits and interest for the delayed period.

The appeal itself was governed by Section 54 of the Land Acquisition Act, 1894.

The Court balanced the strict principles governing limitation against the special context of compulsory acquisition and the landowner’s constitutional and compensatory rights.

Although the delay was inordinate, the Court held that landowners in acquisition matters should not be denied just and reasonable compensation merely on account of delay, particularly where similarly situated landowners had already secured enhanced compensation and the State accepted that the appellant’s claim was covered by the earlier judgment.

At the same time, following the Supreme Court authorities, the Court protected the acquiring authority from liability for interest and statutory benefits attributable to the appellant’s prolonged inaction.

The concession by the State that the claim was covered by RFA-9727-2014 therefore justified allowing the appeal on parity, subject to the exclusion of such benefits.

The appeal was allowed in terms of the judgment dated 29.03.2022 in RFA-9727-2014.

However, the appellant was expressly denied interest for the delayed period of 3,416 days and statutory benefits under the Land Acquisition Act, 1894.

Pending applications, if any, were disposed of.