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Issues: Delay in filing special leave petitions, Condonation of delay under Limitation Act, Application of Land Acquisition (Amendment) Act, 1984, Interpretation of sections 25 and 28A, Justification for reopening of final award, Comparison with previous judgments on limitation.
Analysis: The Supreme Court addressed the issue of delay in filing special leave petitions, emphasizing the importance of condonation under the Limitation Act, 1963. The petitioners sought to rely on the Land Acquisition (Amendment) Act, 1984, specifically sections 25 and 28A, to support their claim for redetermination of compensation. However, the Court found that these provisions did not apply to the petitioners as they were not part of the intended beneficiary class. The petitioners had already received enhanced compensation through civil court proceedings and had not challenged the final judgment for over three years. The Court noted that there was no provision in the Act for reopening a final award except under section 28A, which had specific conditions that were not met by the petitioners. The judgment highlighted that granting special leave based solely on a change in law was not sufficient to condone the delay. Moreover, the Court distinguished the present case from previous judgments, such as Madras Port Trust's case, where the issue of limitation was considered in a different context. The Court emphasized that the government or public authorities could rely on technical pleas like limitation if well-founded, and citizens could not use their own delay as a basis for condonation. The judgment reiterated the importance of upholding legal principles and not granting special leave in cases where there was no justification for condoning significant delays. Ultimately, the Court dismissed the special leave petitions due to the excessive delay and imposed costs on the petitioners, emphasizing the need to adhere to statutory timelines and legal procedures without unjustified leniency.
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