Punjab & Haryana High Court Dismisses Challenge to 1993 Acquisition; Holds 31-Year Delay and Complete Vesting of Land Bar Any Relief

Case Name: Delhi Catholic Archdiocese through its Secretary vs. State of Haryana and Others
Date of Judgment: 02 December 2025
Citation: CWP-25397-2024
Bench: Hon’ble Mr. Justice Deepak Sibal, Hon’ble Ms. Justice Lapita Banerji

Held: The Punjab and Haryana High Court dismissed the writ petition challenging a 1993 land acquisition award, holding that the petition filed after more than three decades was barred by delay, laches and acquiescence. The Court further held that once possession is taken and the land vests in the State, no plea under Section 24(2) of the 2013 Act is maintainable.

Summary: The petitioner society sought quashing of Award No.8 of 1993 and de-notification of land acquired for development of Sector 45, Gurugram. It asserted that no notice under Section 12(2) of the 1894 Act had been served, no compensation had been paid, physical possession had never been taken, and that the land had remained unused for the intended public purpose. The society invoked Section 24(2) of the 2013 Act to contend that the acquisition had lapsed.

The State opposed the petition, pointing out that the acquisition proceedings began in 1990, the declaration followed in 1991, and the award was issued in 1993. It submitted that possession had been taken and handed over to HUDA on the same day, and that the compensation had been duly tendered and later deposited in court. The State also stressed that the land had been incorporated into the approved sector layout and earmarked for civic uses, demonstrating utilisation. The State argued that the petition was wholly belated, as no objection was filed during the acquisition process and no explanation existed for challenging the award after thirty-plus years.

The Court held that the writ petition was untenable due to extraordinary delay and the petitioner’s long acquiescence, applying the principles articulated in binding precedents including Union of India v. N. Murugesan, Brijesh Kumar v. State of Haryana, Mewa Ram v. State of Haryana, and the recent decision in Union of India v. Jahangir Byramji Jeejeebhoy. The Court found that the petitioner had not only approached the Court after an unexplained lapse of 31 years but had also allowed the acquisition to attain finality while the State completed the process of possession, vesting and development planning.

On merits, the Court relied on the Constitution Bench judgment in Indore Development Authority v. Manohar Lal. It reiterated that once possession is taken through the recognized mode and the award is made, the land vests absolutely in the State and Section 24(2) cannot revive concluded proceedings. The Court held that any continued occupation by the petitioner would be nothing more than trespass after vesting.

Decision: The writ petition was dismissed in entirety. The Court held that the extraordinary delay, acquiescence and the complete vesting of land in the State foreclosed any relief, and the acquisition proceedings could not be reopened under Section 24(2) of the 2013 Act.