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(2026) Law Today Live Doc. Id. 20814 = 2026 INSC 138
(arising out of SLP (C) No(s). 215-216 of 2023)
Decided on: 09.02.2026
A. Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 (30 of 2013), Section 74 -- Limitation Act, 1963 (36 of 1963), Section 4-24, 29(2) -- Appeal u/s 74 of Land Acquisition, Rehabilitation and Resettlement Act, 2013 – Applicability of Limitation Act, 1963 -- Section 29(2) of the 1963 Act is mandatory, with the exception arising only by way of an express exclusion -- Therefore, in the absence of the same, Sections 4 to 24 of the said Act can be read into such special or local law -- The 2013 Act does not take away from its purview the application of Sections 4 to 24 of the 1963 Act – The 2013 Act being a subsequent legislation, it is obvious that the Legislature was conscious not to take away the application of Sections 4 to 24 of the 1963 Act from its purview – Section 74 of the 2013 Act does not exclude the application of Sections 4 to 24 of the 1963 Act.
(Para 62, 76, 77)
B. Land Acquisition Act, 1894 (1 of 1894), Section 4, 6, 11, 54 -- Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 (30 of 2013), Section 24(1)(a), 74 -- Acquisition of land under 1894 Act – Award after commencement of 2013 Act – Appeal u/s 74 of 2013 Act will lie -- Section 24(1)(a) of the 2013 Act is applicable to all those cases where awards are passed after the commencement of the 2013 Act -- For passing the award under Section 24(1)(a), the provisions of the 2013 Act alone will have to be followed, except for the rehabilitation and resettlement entitlements -- The first appeals before the High Courts should be treated as ones under Section 74 of the 2013 Act and not under Section 54 of the 1894 Act.
(Para 97 (i)-(iii))
C. Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 (30 of 2013), Section 74, 103 – Limitation Act, 1963 (36 of 1963), Section 5, 29(2) – Appeal u/s 74 of Land Acquisition, Rehabilitation and Resettlement Act, 2013 – Limitation – Condonation of delay -- Section 74 of the 2013 Act does not bar the application of Section 5 of the 1963 Act -- Consequently, all the applications seeking condonation of delay in preferring the first appeals before the High Courts u/s 74 of the 2013 Act stand allowed -- High Courts shall avoid a pedantic approach as against a pragmatic one in dealing with the applications seeking condonation of delay.
(Para 97 (iv)-(viii))