RATTAN SINGH vs UNION OF INDIA

The Supreme Court examined the applicability of Section 24(2) of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013, in relation to land acquisition proceedings initiated under the Land Acquisition Act, 1894. The Court held that for a deemed lapse of acquisition proceedings, it must be established that an Award was made at least five years prior to the commencement of the 2013 Act and that possession was not taken or compensation paid. In this case, the Court found that while the Award was made in 1968, the Appellants failed to demonstrate that compensation was not paid, thus the proceedings were not deemed to have lapsed.