Laxami Devi vs State Of Bihar & Ors

The Supreme Court addressed the necessity of passing an Award under the Land Acquisition Act, 1894, particularly in cases of urgency as per Section 17. The Court held that even in urgent acquisitions, the requirement of an Award is essential to protect individual rights against arbitrary state action. The ruling emphasized that the constitutional protection of property rights must not be undermined by the state's invocation of urgency, and that the state cannot simply repurpose acquired land without due process, reaffirming the principles established in Delhi Airtech Services (P) Ltd. vs. State of U.P. (2011) 9 SCC 354.