Satish Kumar And Anr vs Govt Of Nct Of Delhi & Ors on 5 May, 2026

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    Delhi High Court

    Satish Kumar And Anr vs Govt Of Nct Of Delhi & Ors on 5 May, 2026

    Author: Prathiba M. Singh

    Bench: Prathiba M. Singh

                              $~54
                              *       IN THE HIGH COURT OF DELHI AT NEW DELHI
                                                                              Date of decision: 5th May, 2026
                                                                               Uploaded on: 7th May, 2026
                              +                   W.P.(C) 4957/2026 & CM APPL. 24375/2026
                                      SATISH KUMAR AND ANR                                .....Petitioner
                                                            Through:   Mr. Kamlesh Kumar Mishra, Ms
                                                                       Renu, Mr. Swagata Gupta, Adv.
                                                            versus
    
                                      GOVT OF NCT OF DELHI & ORS.              .....Respondents
                                                   Through: Mr. Sanjay Kumar Pathak SC with
                                                             Mrs. K. Kaomudi Kiran Pathak, Mr.
                                                             Sunil Kumar Jha, Mr. M. S. Akhtar,
                                                             Miss Joohu Kumari & Mr. Kushagra
                                                             Dixit, Advs.
                                                             Mr Arjun Mahajan SC, Ms Monica
                                                             Batra Adv, Mr Apoorv Upmanyu, Mr
                                                             Ravikant Kumar, Advs.
    
                                      CORAM:
                                      JUSTICE PRATHIBA M. SINGH
                                      JUSTICE MADHU JAIN
                              Prathiba M. Singh, J. (Oral)
    

    1. This hearing has been done through hybrid mode.

    2. The present petition has been filed by the Petitioners- Mr. Satish Kumar
    and Mr. Jagdish under Article 226 of the Constitution of India, inter alia,
    assailing the acquisition of land admeasuring 05 Biswas out of total land of 2
    Bighas, 11 Biswas, in Khasra No. 28/4/2 (min.) situated in Village Bamnoli,
    Tehsil Kapashera, District South West (hereinafter, ‘the subject land’).

    SPONSORED

    3. The case of the Petitioners is that the subject land was never acquired

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    by the authorities and possession was also not taken. Further, it is also
    contended that the acquisition of the subject land has lapsed, pursuant to
    Section 24 of the Right to Fair Compensation and Transparency in Land
    Acquisition, Rehabilitation and Resettlement Act, 2013.

    4. Furthermore, Mr. Mishra, ld. Counsel for the Petitioner relies upon the
    document filed before the concerned District Judge, Dwarka Courts,
    concerning the proceedings of the subject land, wherein, the clear stand of the
    LAC is that the possession of subject land was not taken.

    5. On the other hand, Mr. Pathak, ld. Counsel for the Land Acquisition
    Collector (hereinafter, ‘LAC’), relies upon the final judgment of this Court
    dated 15th April, 2019 in W.P.(C) 1643/2016 titled ‘Satish Kumar and Ors.
    v. Govt of NCT of Delhi and Ors.
    ‘. Vide the said judgment, the issue raised
    in the present petition has already been considered by a Coordinate bench of
    this Court, and it was held that no relief would be liable to be granted.

    6. The Court has considered the matter. A perusal of the final judgment
    dated 15th April, 2019 in Satish Kumar and Ors. (Supra) would show that in
    the said judgment, all the aspects which are today sought to be canvassed in
    the present petition, have already been considered by a Coordinate bench of
    this Court.

    7. The relevant portions of the judgement dated 15th April, 2019 in Satish
    Kumar and Ors.
    (Supra) are set out below:

    “2. The Petitioners state that they are the recorded
    owners of the aforementioned land ad-measuring 01
    bigha and 01 biswa comprising in khasra No.
    28//4/1 min., situated in Village-Bamnoli, District-
    South-West, New Delhi. It is stated that the
    Petitioners Nos. 1 and 2 are co-owners of land
    admeasuring 5 biswas, each of them having half

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    share. The Petitioner Nos. 3 to 5 are stated to be the
    owners of 04 biswas each and the predecessors-in-
    interest of Petitioner No.6 (i) to (vii) was the owner
    of 04 biswas. It is stated that the khasra No. 28//4/1
    min. is the post consolidation number after the
    acquisition proceedings took place in the said
    village in 1997.

    3. The land in question was sought to be acquired
    by issuance of a notification dated 4th November
    2004 under Section 4 of the Land Acquisition Act,
    1894 (‘LAA’). This notification was in respect of
    2100 bighas and 06 biswas of land in village-
    Bamnoli and was for the public purpose of Dwarka
    Phase-II. This was followed by a declaration under
    Section 6 LAA on 31st October 2005. The Award
    No. 01/2007-08 was passed on 6th August 2007.

    4. Earlier, Petitioners 1 to 5 filed
    W.P.(C)6686/2007 challenging the
    aforementioned Award. The said writ petition was
    dismissed by this Court on 16th May 2008.

    5. The Petitioners claim that compensation qua 01
    biswa of land in khasra No. 28//4/1 min. was paid to
    Petitioner Nos. 3 to 5 and that payment qua
    remained 03 biswas was withheld on some pretext.
    It was claimed that compensation was never offered
    to Petitioner Nos.1, 2 and 6. It is further stated that
    the Land Acquisition Collector (‘LAC’) deposited
    the compensation amount in the Court of the learned
    Additional District Judge (‘ADJ’) in August 2010.
    By a judgment dated 11th July 2011, the learned
    ADJ disposed of the reference permitting the
    interested persons and the land owners with liberty
    to withdraw the compensation qua the respective
    lands against bank guarantee. A separate order was
    made in that regard by the learned ADJ for the

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    interest amount.

    6. It is stated that the further application filed by the
    interested persons before the learned ADJ for
    modification of the order dated 11th July 2011 was
    disposed of by permitting them to withdraw the
    compensation against their individual security
    rather than bank guarantee. The LAC thereafter on
    25th September 2013 deposited Rs. 2,99,03,662/- by
    a cheque dated 3rd September 2013.

    7. The Petitioners stated that the LAC itself
    informed the Reference Court that as far as the
    Petitioner Nos.1 and 2 was concerned out of the
    total land of 02 bighas 11 biswas, possession of 05
    biswas was not taken and accordingly the
    corresponding payment for that extent of land has
    not been released. As regards Petitioner 6 (i) to

    (vii), of the total land of 02 bighas and 10 biswas,
    possession of 04 biswas was not taken. The
    Petitioners state that compensation for the land not
    yet taken possession of has not been paid till now.

    It is on the above basis it is contended on behalf of
    the Petitioners that notwithstanding the dismissal
    of the earlier writ petition challenging the Award,
    they would be entitled to a declaration of deemed
    lapsing of land acquisition proceedings under
    Section 24 (2) of The Right to Fair Compensation
    and Transparency in Land Acquisition,
    Rehabilitation and Re-settlement Act, 2013. (‘the
    2013 Act’).

    8. The counter affidavits filed by both LAC and DDA
    consistently maintain that possession of the land in
    question was taken on 6th May 2010, although, the
    possession proceedings, therefore, have not been
    enclosed. The further consistent stand is regarding
    the deposit of the compensation amount in the Court

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    of the learned ADJ. The details of the actual
    compensation paid to some of the land
    owners/interested persons have also been set out in
    paragraph 8 of the reply filed by the LAC. This has
    been corroborated in a separate reply filed by the
    DDA. The rejoinder affidavits of the Petitioners are
    a mere reiteration of the averments in the petition.

    9. There are several difficulties in granting the
    Petitioners the relief as prayed for by them. In the
    first place as regards possession of the lands which
    they claim has not been taken, it is seen that it
    comprises only a small portion of the entire extent
    land sought to be acquired by the Respondents.
    Even in this regard the question whether the LAC
    took over the possession of the entire land on 6th
    May 2010, or as contented by the Petitioners, a
    small extent was still left with the Petitioners, is a
    disputed question of fact which cannot possibly be
    examined in these proceedings.

    10. Even as regards compensation, considering
    that the learned ADJ passed a final order in the
    reference, followed by an order regarding payment
    of interest thereon, it cannot be said in this case
    that no compensation was ever tendered by the
    LAC. Therefore, it is not possible to agree with the
    Petitioners that the either of the two conditions for
    attracting Section 24 (2) of the 2013 Act stand
    conclusively fulfilled. On the contrary, on the facts
    of the present case, the Petitioners have failed to
    make out a convincing case that neither has
    compensation been tendered nor has the
    possession been taken of the entire lands in
    question by the Respondents.

    11. Apart from the disputed questions of fact, the
    Petitioners having earlier been unsuccessful in

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    challenging the land acquisition proceedings,
    cannot be permitted to have an another round of
    litigation, this time for seeking the deemed lapsing
    of the land acquisition proceedings. In this context
    the following observations of the Supreme Court in
    Indore Development Authority v. Shailendra
    (2018) 3 SCC 412 are relevant:

    “130. We are of the view that stale or
    dead claims cannot be the subject-matter
    of judicial probing under section 24 of the
    Act of 2013. The provisions of section 24
    do not invalidate those judgment/orders
    of the courts where under rights/claims
    have been lost/negatived, neither do they
    revive those rights which have come
    barred, either due to inaction or
    otherwise by operation of law.

    Fraudulent and stale claims are not at all
    to be raised under the guise of section 24.
    Misuse of provisions of section 24(2)
    cannot be permitted. Protection by the
    courts in cases of such blatant misuse of
    the provisions of law could never have
    been the intention behind enacting the
    provisions of section 24 (2) of the 2013
    Act; and, by the decision laid down in
    Pune Municipal Corporation (supra), and
    this Court never, even for a moment,
    intended that such cases would be
    received or entertained by the courts.”

    12. It may be noted here that the reference made by
    a Constitution Bench in Indore Development
    Authority v. Shyam Verma
    (2018) 4 SCC 405
    regarding the correctness of the aforesaid decision
    in Indore Development Authority v. Shailendra
    (supra) is only as regards the extent to which it
    differs from the earlier view of the Supreme Court

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    in Pune Municipal Corporation v. Harakchand
    Misrimal Solanki
    (supra) regarding the tendering
    of compensation, and on certain other issues but not
    on the question of petitions seeking declaration
    under Section 24 (2) of the 2013 Act being barred
    by laches. This legal position was explained by this
    Court recently in Mool Chand v. Union of India
    2019 (173) DRJ 595 DB.

    13. For the aforementioned reasons, this petition
    is dismissed. The interim order dated 26th
    February 2016 which stood confirmed on 18th
    January 2018 stands vacated.”

    8. Thus, the issue pertaining to the subject land of 05 biswas has already
    been considered by this Court, as evident from paragraph 7, extracted
    hereinabove.

    9. In addition, the Coordinate bench of this Court has also considered the
    decision of the Supreme Court in Indore Development Authority v. Manohar
    Lal & Ors., (2020) 8 SCC 129 and has held that the petition would not be
    maintainable.

    10. Accordingly, the same issue cannot now be canvassed in a fresh writ
    petition, which would be the third round.

    11. Under these circumstances, the present petition is not maintainable and
    is accordingly dismissed.

    12. If any remedy for claiming compensation is still available, the
    Petitioners are at liberty to avail of the same, in accordance with law.

    13. If such a claim for compensation is filed by the Petitioners, the LAC
    shall verify whether the compensation in respect of the subject land has been
    paid or not and if not, the same shall be released to the Petitioner.

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    14. The present petition is disposed of in these terms. Pending
    applications, if any, are also disposed of.

    PRATHIBA M. SINGH
    JUDGE

    MADHU JAIN
    JUDGE
    MAY 5, 2026/prg/sm

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