The Supreme Court overturned the High Court decision quashing the land acquisition notifications by the Haryana Urban Development Authority (HUDA). The judgment emphasized compliance with Section 5A of the Land Acquisition Act, 1894, stating that landowners were duly heard, but relief was not guaranteed. The apex court rejected the plea of discrimination and confirmed the legality of the acquisition process, asserting that public interest supersedes individual landownership concerns. It dismissed the compromise reached between the parties, upholding the government’s power to proceed with the acquisition.

1. Introduction of the Case (Paras 1-2):
   The Haryana Urban Development Authority (HUDA) appealed against the High Court's decision to quash the land acquisition notifications under Sections 4 and 6 of the Land Acquisition Act, 1894. The State intended to acquire land for residential, commercial, and recreational development in Panchkula, Haryana.

2. Land Acquisition Background (Paras 2-5):
   In 1999, a notification was issued to acquire 952.18 acres of land in villages near Panchkula. The respondents claimed exemption from acquisition due to the presence of fruit trees and authorized structures, but the State proceeded with the acquisition, asserting the structures were unauthorized.

3. High Court’s Judgment (Para 7):
   The High Court quashed the acquisition, finding that the respondents' objections were wrongfully rejected and citing discriminatory treatment since similar land belonging to Maharaja Harinder Singh was exempted.

4. Contentions by Appellants (Paras 9-10):
   HUDA argued that the constructions were unauthorized, no discrimination occurred, and the acquisition was in public interest, citing previous court rulings that support the State’s authority to acquire land even with pre-existing structures.

5. Supreme Court’s Analysis (Paras 12-26):
   The Court highlighted that the procedural requirements under Section 5A of the Land Acquisition Act were met, confirming that the respondents’ objections were heard but the decision to acquire was lawful. The Court rejected the argument that the Collector’s recommendation should bind the State, emphasizing that the final decision rested with the government.

6. Discrimination Claim (Paras 27-31):
   The Court dismissed the claim of discrimination, noting that almost the entire land area was acquired, and any previous exemption was later corrected by subsequent acquisition. The doctrine of negative equality (seeking benefits because of another's exemption) was deemed inapplicable.

7. Compromise Rejected (Paras 32-46):
   The Court scrutinized the compromise reached between the parties, observing that it undermined public interest. The process leading to the State’s decision to release the land was deemed arbitrary and lacked thorough consideration of its impact on the overall acquisition.

8. Doctrine of Merger (Paras 47-53):
   The Court applied the doctrine of merger to hold that the previous appeals against the same High Court judgment had been dismissed, but invoked its powers under Article 142 of the Constitution to ensure complete justice, thereby bypassing the doctrine’s technical application.

Key Acts and Sections Discussed:

• Land Acquisition Act, 1894, Sections 4 and 6:
  Notifications were issued to acquire land, but they were challenged on the basis of procedural violations under the Act.

• Section 5A of the Land Acquisition Act, 1894:
  This section, which grants landowners the right to object to acquisition, was central to the case. The Court held that the State had duly complied with the procedure, although the objections did not necessitate release.

• Punjab Periphery Act, 1952:
  The Court discussed the respondents' reliance on this act, arguing that agricultural constructions were exempted, but these permissions were found to be conditional and not applicable to residential developments.

Ratio Decidendi:
The Supreme Court upheld that Section 5A of the Land Acquisition Act mandates a hearing of objections, but not necessarily the release of land. The government's power to acquire land for public purposes remains intact, even if there are authorized structures on the land. Discrimination claims cannot justify exemption from acquisition, especially when they could undermine larger public interest.

Subjects:
Land Acquisition, Public Purpose, Section 5A of the Land Acquisition Act, 1894, Doctrine of Merger, Discrimination under Article 14 of the Constitution.

Land Acquisition, Haryana Urban Development Authority, Supreme Court, Land Law, Eminent Domain, Public Interest, Property Rights, Indian Constitution Article 14.