LAXMI CHAND vs INDORE IMPROVEMENT TRUST, INDORE AND ORS.

The Supreme Court held that under Section 31 of the Madhya Pradesh Town Improvement Trust Act, 1960, a housing accommodation scheme can incorporate features of an industrial scheme, and there is no prohibition against combining such schemes. The Court found that the Trust's refusal to grant a No Objection Certificate for industrial development was unjustified, and the acquisition of land was not malafide. Furthermore, the Court ruled that the Act does not provide for interest payment from the date of possession to compensation determination, thus not violating Article 31(2) of the Constitution.