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◈ VaadHan AI Synthesis · S.24(2) Land Acquisition · AP Focus
"Under Section 24(2) of the RFCTLARR Act 2013, acquisition lapses if compensation was not paid
and possession not taken for five years. The Supreme Court in Indore Development Authority v. Manoharlal
(2020) 8 SCC 129 clarified — applying an 'or' rather than 'and' reading —
that lapse requires both non-payment and non-possession conjunctively.
AP High Court consistently follows this five-judge bench ruling, with particular emphasis
on the date of award publication as the trigger point."
S.24(2) RFCTLARR 2013
5J Constitution Bench
AP HC — Binding
Lapse of Acquisition
AI synthesis · Verify citations independently · Not legal advice · IndianKanoon + SCC Online
Indore Development Authority v. Manoharlal & Ors.
97%
Relevance
"The word 'or' in S.24(2) must be read as 'and' — lapse of acquisition requires both non-payment of compensation and non-possession conjunctively over the five-year period."
Pune Municipal Corp. v. Harakchand Misirimal Solanki
91%
Relevance
"Original ruling on S.24(2) — 'or' reading — acquisition lapses if either compensation unpaid or possession not taken. Overruled in part by Indore Dev. Auth. (2020) Constitution Bench."
Revenue Dept., AP v. K. Kondaiah & Ors.
88%
Relevance
"Applying Indore Dev. Auth., AP HC held that deposit of compensation in court treasury does not constitute 'payment' under S.24(2); direct payment to landowner required."
Narsimha Reddy v. Collector, Guntur
82%
Relevance
"Five-year period under S.24(2) runs from date of award under 1894 Act, not from 2013 Act commencement. Delay by State in drawing award is no excuse."
Shiv Kumar Bhargava v. Union of India
74%
Relevance
"Post-Indore, the enquiry for lapse must be whether both conditions in S.24(2) — non-payment AND non-possession — are established cumulatively."