THE STATE OF GUJARAT STATE OF GUJARAT vs JAYANTIBHAI ISHWARBHAI PATEL

The Supreme Court examined whether the land acquisition process under the Land Acquisition Act, 1894, was valid when the land was deemed to have lapsed under Section 24(2) of the Land Acquisition, Rehabilitation and Resettlement Act, 2013. The High Court of Gujarat had declared the acquisition to have lapsed, and the State challenged this decision. The Court analyzed the applicability of Section 24(2) of the 2013 Act to proceedings initiated under the 1894 Act and upheld the High Court's decision, affirming that the acquisition had indeed lapsed. The judgment clarifies the transition provisions and the effect of the 2013 Act on ongoing land acquisitions under the earlier law.