Punjab and Haryana High Court condones 4,099-day delay, grants landowners enhanced compensation but denies interest and statutory benefits for the delayed period

The appellants, landowners, challenged the award dated 21 April 2015 passed by the Additional District Judge, Kaithal, which did not grant them the claimed enhanced compensation under the Land Acquisition Act, 1894.

The appeal was filed with an application seeking condonation of 4099 days’ delay, on the ground that the appellants were unaware of the status of the proceedings and that similarly situated landowners had obtained enhanced compensation in appeals decided by the High Court.

The State conceded that the appellants’ claim was covered by the judgment dated 30 March 2026 in RFA-5409-2015, but relied on Supreme Court precedent to contend that the appellants could not receive statutory benefits or interest for the period of delay.

Whether the delay of 4099 days in filing the first appeal under Section 54 of the Land Acquisition Act, 1894 ought to be condoned?

Whether, after condonation of the delay, the appellants were entitled to enhanced compensation in terms of the decision in RFA-5409-2015?

Whether the appellants were entitled to statutory benefits and interest for the delayed period?

The Court applied Sections 3 and 5 of the Limitation Act, 1963, holding that limitation serves the public policy of finality, while Section 5 permits a discretionary and liberal exercise of power where sufficient cause is shown; however, inordinate delay, negligence, and lack of due diligence remain relevant considerations, and merits ordinarily should not determine a delay-condonation application, as explained in Pathapati Subba Reddy (Died) by LRs v. Special Deputy Collector, 2024 (12) SCC 336.

The Court also relied on Shivamma (Dead) v. Karnataka Housing Board, 2025 SCC OnLine SC 1969, which cautions against mechanically condoning exceptionally long delays.

In land-acquisition matters, however, 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, recognise that enhanced compensation may be granted despite delay, while statutory benefits and interest for the delayed period should not be imposed on the acquiring body.

The Court further relied on Urban Improvement Trust v. Vidhya Devi, 2024 SCC OnLine SC 3725, for the principle that landowners’ claims involving the constitutional right to property under Article 300-A should generally be adjudicated liberally on merits rather than defeated by a hyper-technical approach to delay.

The appeal itself was maintainable under Section 54 of the Land Acquisition Act, 1894.

Although the delay was exceptionally long, the Court distinguished land-acquisition appeals from ordinary limitation cases and adopted a liberal, justice-oriented approach because the appellants sought parity with similarly situated landowners whose claims had already succeeded.

Balancing the appellants’ right to fair compensation for acquired property against the prejudice and financial burden to the acquiring authority, the Court condoned the 4099-day delay but applied the safeguard recognised in New Okhla Industrial Development Authority and Suresh Kumar: the acquiring body could not be burdened with statutory benefits or interest attributable to the appellants’ delayed approach to the Court.

Since the State expressly conceded that the substantive claim was covered by the earlier decision in RFA-5409-2015, the Court allowed the appeal on the same terms without undertaking any independent merits analysis.

The appeal was consequently allowed in terms of the High Court’s order dated 30 March 2026 in RFA-5409-2015.

However, the appellants were held not entitled to statutory benefits or interest for the delayed period of 4099 days.

Any pending miscellaneous applications were disposed of.