PATNA IMPROVEMENT TRUST vs SMT. LAKSHMI DEVI & OTHERS

The Supreme Court addressed whether the Bihar Town Planning and Improvement Trust Act, 1951, replaced the Land Acquisition Act, 1894, regarding land acquisition for the Trust. The Court held that the notifications issued under Sections 4 and 6 of the Land Acquisition Act remained valid, as Section 71 of the Bihar Act modified but did not exclude the Land Acquisition Act. The Court emphasized that the Trust must acquire land in accordance with the prescribed manner under the Land Acquisition Act, affirming the applicability of its provisions for the Trust's purposes.