Govt. Of Nct Delhi vs. Ombir Singh

Court:Supreme Court of India
Judge:Hon'ble M.R. Shah, Krishna Murari
Case Status:Disposed
Order Date:25 Jul 2022
CNR:SCIN010183552022

AI Summary

The Supreme Court has issued notice in a Special Leave Petition challenging a Delhi High Court order, which relied on a decision subsequently overruled by a Constitution Bench. This signals a potential review of the High Court's judgment, particularly concerning the applicability of the landmark 'Indore Development Authority' case on land acquisition.

Ratio Decidendi:
Where an impugned judgment of a lower court relies upon a Supreme Court precedent that has been subsequently overruled by a Constitution Bench, it presents a prima facie arguable point warranting the issuance of notice in a Special Leave Petition for further consideration.

Case Identifiers

Primary Case No:Diary No. 3097/2022
Case Type:Special Leave Petition (Civil)
Case Sub-Type:SLP - Land Acquisition Dispute
Secondary Case Numbers:SLP(C) No. 016946/2022, SLP (C) D. NO. 36460/2018
Order Date:2022-07-25
Filing Year:2022
Court:Supreme Court of India
Bench:Division Bench
Judges:Hon'ble M.R. Shah, Hon'ble B.V. Nagarathna

Petitioner's Counsel

Chandra Prakash
Advocate on Record - Appeared
Vivek Singh
Advocate - Appeared
C.P. Rajwar
Advocate - Appeared
Abhishek Chaterjee
Advocate - Appeared

Advocates on Record

Chandra Prakash

eCourtsIndia AITM

Brief Facts Summary

The Govt. of NCT of Delhi filed a Special Leave Petition challenging an order of the High Court of Delhi dated October 10, 2018. The petitioner contends that the High Court, in passing its impugned order, relied on a Supreme Court decision in 'Pune Municipal Corporation' which has since been overruled by a Constitution Bench of the Supreme Court in 'Indore Development Authority'.

Timeline of Events

2014

Supreme Court rendered decision in Pune Municipal Corporation case.

2018-10-10

High Court of Delhi passed impugned order in WP(C) No. 19/2018, relying on Pune Municipal Corporation.

2018

Supreme Court Constitution Bench rendered decision in Indore Development Authority, overruling Pune Municipal Corporation.

2022-07-25

Supreme Court hears Special Leave Petition (Civil) Diary No. 3097/2022, challenging the High Court order.

Key Factual Findings

The High Court, in its impugned judgment, relied upon the decision of this Court in 'Pune Municipal Corporation and Another vs. Harakchand Misirimal Solanki and Others, (2014) 3 SCC 183'.

Source: Recited from Petitioner Pleading

The 'Pune Municipal Corporation' decision has been subsequently overruled by the Constitution Bench decision of this Court in 'Indore Development Authority vs. Manoharlal and Others, (2018) 8 SCC 129'.

Source: Current Court Finding

Primary Legal Issues

1.Applicability of overruled Supreme Court precedents by lower courts.
2.Correct interpretation and application of land acquisition laws in light of the 'Indore Development Authority' Constitution Bench decision.
3.Validity of a High Court judgment relying on a Supreme Court decision subsequently overruled.

Secondary Legal Issues

1.Condonation of delay in filing a Special Leave Petition.
2.Procedural requirements for service of notice in the Supreme Court.

Statutes Applied

Land Acquisition Act, 1894
Sections pertaining to lapsing of acquisition or compensation (inferred)
Dispute over the lapsing of land acquisition proceedings due to non-deposit of compensation or non-taking of possession, as per the legal framework.
Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013
Section 24 (inferred from cited cases)
Interpretation of Section 24 concerning conditions for lapsing of land acquisition proceedings under the new law, as clarified by the Constitution Bench.

Petitioner's Arguments

The petitioner argues that the impugned judgment of the High Court is flawed because it relied on the 'Pune Municipal Corporation' decision, which has since been expressly overruled by the Constitution Bench in 'Indore Development Authority'.

Court's Reasoning

The Court acknowledged the petitioner's submission regarding the High Court's reliance on an overruled Supreme Court precedent ('Pune Municipal Corporation') and the subsequent binding nature of the Constitution Bench decision ('Indore Development Authority'). In light of this, the Court found it appropriate to issue notice in the Special Leave Petition and the application for condonation of delay.

Judicial Philosophy Indicators:
  • Emphasis on Correct Application of Precedent
  • Strict Adherence to Binding Authority
Order Nature:Procedural
Disposition Status:Pending

Impugned Orders

High Court Of Delhi at New Delhi
Case: WP(C) No. 19/2018
Date: 2018-10-10

Specific Directions

  1. 1.Issue notice on the application for condonation of delay as well as on the Special Leave Petition, making it returnable on 06.09.2022.
  2. 2.Dasti service, in addition, is permitted.
  3. 3.The respondents be served within a period of one week from today.
  4. 4.To be heard and notified with SLP (C) D. NO. 36460/2018 and other allied matters.

Precedential Assessment

Non-Binding (Procedural)

This is an interim procedural order issuing notice and tagging, not a substantive decision on the merits of the case.

Tips for Legal Practice

1.Always verify the current status of precedents, especially those cited in impugned orders, as Supreme Court decisions can be overruled by larger benches.
2.Timely filing of SLPs is crucial, and condonation of delay applications must be robustly supported, especially when challenging orders based on overruled law.
3.Be prepared for cases to be tagged with other similar matters, particularly those concerning landmark Constitution Bench judgments on significant legal issues.

Legal Tags

Land acquisition compensation lapsing legal principlesOverruled precedent application by High CourtsIndore Development Authority binding Constitution BenchSpecial Leave Petition land dispute challengeSection 24 Right to Fair Compensation Act interpretationJudicial review of High Court reliance on outdated lawSupreme Court procedural order condonation of delay
Pune Municipal Corporation and Another vs. Harakchand Misirimal Solanki and Others, (2014) 3 SCC 183
Pune Municipal Corporation and Another v. Harakchand Misirimal Solanki and Others
2014this Court
Principle regarding lapsing of land acquisition proceedings if compensation not paid or possession not taken within specified time, which was the previous position of law.
Overruled
Indore Development Authority vs. Manoharlal and Others, 20) 8 SCC 129
Indore Development Authority v. Manoharlal and Others
2018this Court
Clarified interpretation of Section 24 of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013, concerning conditions for lapsing of acquisition.
Relied Upon

Disclaimer: eCourtsIndia (ECI) is not a lawyer and this analysis is generated by ECI AI, it might make mistakes. This is not a legal advice. Please consult with a qualified legal professional for matters requiring legal expertise.

Order Issued After Hearing

Purpose:

First Hearing

Listed On:

25 Jul 2022

Original Order Copy

Get a certified copy of this order

Download True Copy

Order Text

COURT NO.11

SUPREME COURT OF INDIA RECORD OF PROCEEDINGS

SPECIAL LEAVE PETITION (CIVIL) Diary No. 3097/2022

(Arising out of impugned final judgment and order dated 10-10-2018 in WP(C) No. 19/2018 passed by the High Court Of Delhi at New Delhi)

GOVT. OF NCT OF DELHI

Petitioner(s)

VERSUS

VIKAS & ORS.

Respondent(s)

(FOR ADMISSION and I.R. and IA No.77676/2022-CONDONATION OF DELAY IN FILING and IA No.77677/2022-EXEMPTION FROM FILING O.T. ) Date: 25-07-2022 This petition was called on for hearing today. CORAM : HON'BLE MR. JUSTICE M.R. SHAH HON'BLE MRS. JUSTICE B.V. NAGARATHNA For Petitioner(s) Mr. Chandra Prakash, AOR Mr. Vivek Singh, Adv. Mr. C.P. Rajwar, Adv. Mr. Abhishek Chaterjee, Adv.

For Respondent(s)

UPON hearing the counsel the Court made the following $0 R D E R$

Learned counsel appearing on behalf of the petitioner has submitted that, while passing the impugned judgment order, the High Court has relied upon the decision of this Court in the case of Pune Municipal Corporation and Another vs. Harakchand Misirimal Solanki and Others, (2014) 3 SCC 183 which has been subsequently overruled by the Constitution Bench decision of this Court in the case of Indore Development Authority vs. Manoharlal and Others, 20) 8 SCC 129.

In that view of the matter, issue notice on the application

<pre>contd..</pre>

for condonation of delay as well as on the Special Leave Petition, making it returnable on 06.09.2022.

Dasti service, in addition, is permitted.

The respondents be served within a period of one week from today.

To be heard and notified with SLP (C) D. NO. 36460/2018 and other allied matters.

(NEETU SACHDEVA) (NISHA TRIPATHI) ASTT. REGISTRAR-cum-PS ASSISTANT REGISTRAR

Share This Order

Case History of Orders

Order(6) - 26 Sept 2022

ROP - of Main Case

Click to view

Order(7) - 26 Sept 2022

Judgement - of Main Case

Click to view

Order(5) - 22 Sept 2022

ROP - of Main Case

Click to view

Order(2) - 25 Jul 2022

ROP

Click to view

Order(3) - 25 Jul 2022

ROP

Viewing

Order(4) - 25 Jul 2022

ROP

Click to view

Order(1) - 20 Jul 2022

ROP - of Main Case

Click to view
Similar Case Search