Indore Development Authority And Etc. vs Manoharlal And Ors. Etc.

The Supreme Court referred the interpretation of Section 24 of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 to a five-Judge Constitution Bench, noting that previous judgments, including Pune Municipal Corporation & Anr. v. Harakchand Misirimal Solanki & Ors. (2014) and Yogesh Neema & Ors. v. State of Madhya Pradesh (2016), had not adequately addressed critical aspects of the section. The Court clarified that 'paid' in Section 24 has the same meaning as 'tender of payment' in Section 31(1) of the Land Acquisition Act, 1894, and that non-deposit of compensation in court does not lead to a lapse of acquisition under Section 24(2). The majority opinion concluded that the previous interpretation was per incuriam and warranted further examination by a larger bench.