Bombay High Court

Reservation Lapses Automatically Under Section 127 of MRTP Act if Acquisition Not Initiated Within Statutory Period

Darpan Narendra Thakur vs State Of Maharashtra Thr The Urban Development And Town Planning Dept And Ors

Bombay High CourtJUDGMENT: April 22, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The Petitioner owns land at Survey No. 317 (Hissa No. 3, 4 & 12E) in Virar, Palghar

Source reference: p. 1-2

Under the Development Plan sanctioned on February 9, 2007, the land was reserved for a Market Garden, Community Center, and a 20-meter D.P. Road

Source reference: p. 2, para. 4

The Respondents failed to acquire the land within the statutory ten-year period, which expired on February 9, 2017

Source reference: p. 3, para. 4

Consequently, the Petitioner served a purchase notice under Section 127 of the MRTP Act on March 28, 2018

Source reference: p. 3, para. 4

The Respondents did not respond or initiate acquisition within the statutory timeframe following the notice

Source reference: p. 3, para. 4.1

In March 2025, during the pendency of this petition, the Corporation admitted the reservation had lapsed but offered compensation only in the form of TDR due to budgetary constraints

Source reference: p. 3, para. 5-5.1
02

Issues

1. Whether the reservation on the Petitioner's land lapsed by operation of law due to the Respondents' failure to acquire the land within the statutory period following the Section 127 notice

Source reference: p. 2, para. 2

2. Whether the Respondents are legally obligated to notify the lapsing of the reservation in the Official Gazette

Source reference: p. 5, para. 10(b)
03

Law Applied

The court applied Section 127 of the Maharashtra Regional and Town Planning Act, 1966 (MRTP Act), which dictates that if reserved land is not acquired within ten years of the Development Plan and further within twenty-four months (as per the amended act) of a valid purchase notice, the reservation shall be deemed to have lapsed

Source reference: p. 2, 4

It relied on the precedent in Shivgonda Anna Patil v. Sangli Miraj and Kupwad City Municipal Corporation (2023), confirming that the effect of lapsing is automatic and does not require a judicial declaration

Source reference: p. 4, para. 8
04

Reasoning

The Court found that the ten-year period for acquisition ended in 2017, and the Petitioner thereafter served a valid notice under Section 127 in 2018

Source reference: p. 3

The Respondents failed to take effective steps toward acquisition within the subsequent statutory period.

Source reference: no citation

The Court dismissed the Corporation’s 2025 communication—offering TDR in lieu of monetary compensation—as a "purely an afterthought" intended to create a record after a significant delay

Source reference: p. 4, para. 5.2

The Court observed that the authorities ignored settled law and harassed the citizen by failing to notify the lapsing

Source reference: p. 4, para. 7, 9

Since the statutory conditions of Section 127 were met, the reservation lapsed automatically by operation of law, regardless of the Corporation's internal budgetary constraints

Source reference: p. 3, para. 5; p. 4, para. 6
05

Holding

The Court allowed the petition, declaring that the reservation on the Petitioner’s land has lapsed under Section 127(1) of the MRTP Act

The Court held that the consequences of a purchase notice are automatic and mandatory

Source reference: p. 4, para. 8

The State Government was directed to notify the lapsing of the reservation by publishing it in the Official Gazette as per Section 127(2) of the MRTP Act within six weeks

Source reference: p. 5, para. 10(b)

Rule was made absolute

Source reference: p. 5, para. 11
Bombay High Court

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Darpan Narendra ThakurvsState Of Maharashtra Thr The Urban Development And Town Planning Dept And Ors

Bombay High Court · April 22, 2026

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