M/S. COMPETENT AUTOMOBILES CO. LTD. vs UNION OF INDIA .

The Supreme Court addressed appeals concerning land acquisition proceedings under the Land Acquisition Act, 1894, and the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013. The Court held that for a declaration of lapse under Section 24(2) of the 2013 Act, it must be established that an Award under Section 11 of the 1894 Act was made before 01.01.2009 and that possession was not taken or compensation paid. The Court emphasized the necessity of factual clarity regarding these conditions before recognizing any statutory lapse of acquisition.