M/S. Competent Automobiles Co. Ltd vs Union Of India & Ors

The Supreme Court ruled that for the lapse of land acquisition proceedings under Section 24(2) of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013, it is essential to establish that an Award under Section 11 of the Land Acquisition Act, 1894 was passed before 01.01.2009 and that possession was not taken or compensation was not paid. The Court emphasized that these factual determinations must precede any declaration of lapse. The judgment also clarified that the statutory rights of landholders under Section 24(2) cannot be overridden by subsequent ordinances without retrospective effect, reaffirming the principles established in prior cases such as Pune Municipal Corporation vs. Harakchand Misirimal Solanki and Union of India vs. Shiv Raj.