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A COMPARATIVE ANALYSIS ON LAND AQUISITION ACT OF INDIA – THE LAND ACQUISITION ACT, 1894, RFCT LAR&R 2013 AND RFCT LAR&R 2015

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Author: Mohit Bhandari, St Joseph’s College of law, 3rd Bcom LLB

ABSTRACT

Land is essential for livelihood, identity and dignity leading to land acquisition as a public infrastructure challenge between the state’s power of eminent domain and welfare of citizen. This paper critically analyses the evolutionary process of laws related to land acquisition in India and traces the paradigm shift from the colonial era Land Acquisition Act, 1894 to rights-based Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement (RFCTLARR), 2013 and the subsequent Amendment Bill in 2015. 

The 1894 Act, facilitated arbitrary acquisition by the state by ambiguous definitions of public purpose, inadequate compensation and absence of rehabilitation framework, leading to displacement of vulnerable agricultural communities. The Act of 2013, introduced Social Impact Assessments, strict consent provisions, enhanced compensation mechanisms, rehabilitation and resettlement, which was significant move towards transparent governance. 

The analysis and examination of landmark judicial precedents notably Kedar Nath Yadav v. State of West Bengal and Kolkata Municipal Corporation V. Bimal Kumar Shah, highlight the procedural safeguard reinforced by the judiciary. These rulings assert that Right to Property under Article 300A of the Constitution includes wide-range of Sub-rights that protect landowners against arbitrary state deprivation.  The paper evaluates 2015 Amendments which aimed to expedite critical infrastructure acquisitions by excluding some categories from the SIA and consent requirements. 

Keywords: The doctrine of eminent domain, The Land Acquisition Act, 1894, The Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 and The Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act 2015 (Amendment Bill), Social Impact Assessment (SIA), rehabilitation and resettlement, compensation.

INTRODUCTION

Land in India is viewed not just as an asset but also as a source of livelihood, dignity, and identity for millions. One of the major challenges in improving and infrastructure in India is securing land necessary for development projects. No other nations can be said to be completely following a set of rules and practices for land acquisition that balances both national development and with the welfare of the people affected by the acquisition. Nearly all countries worldwide hold the authority to acquire private property for public interest and in turn, the landlord is paid compensation by the appropriate government. The Doctrine of Eminent domain is enforced under Entry 42 of Concurrent List od India. Therefore, it empowers both the central and state government’s authority to make laws with respect to acquisition of land.

Various jurists and statue have defined land. The following are:
Salmond’s definition of Land – “Land includes not only the soil but everything that is attached to the earth, whether by nature or by human hand.”

According to Blackstone (Commentaries on the Laws of England) – “Land includes not only the face of the earth, but everything under it or over it. It comprehends all the things of permanent, substantial nature; everything which may be regarded as part of earth.”

According to the Land Acquisition Act, 1894, and RFCT LAR&R 2013 – “Land includes benefits to arise out of land, and things attached to the earth or permanently fastened to anything attached to the earth.”

Land acquisition is the process whereby the government acquires the private land for public purpose or for projects that serves the larger interest of the public. Therefore, the transfer of the ownership of a private land to the government for the benefit of the public or public purpose, such as infrastructure, strategic plans or development. 

Historically, land acquisition in India was governed under the Land Acquisition Act, 1894, but overtime it came to be arbitrary in acquiring land and injustice which resulted in the enactment of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 (RFCT LAR&R 2013)

HISTORICAL BACKGROUND

The history of land acquisition in India can be traced back to the Bengal Regulation I of 1824. It was the time when for the first time the British began acquiring lands for the cause of public welfare. This act was made enforceable in the provinces which were under control of Fort Williams. Later with the Building Act XVIII in 1839 land acquisition began in Bombay. After the first 7 sections of the Bengal Regulation I of 1824 was amended in 1852 a new Madras Act XX of 1852 was passed. The main reasons for acquiring land then were for public welfare which included widening roads, building canals etc.,

After 1850 when the railways were introduced in India, acquiring land for building railways became another cause of land acquisition for public purposes and welfare. But in the year 1857 a new law, Act VI was enacted which abolished all the previous acts on the land acquisition. The East Indian Company wanted to improve the process and for the first time mentioned the word “compensation” under the Act. According to this law, the collector had authority to assess and determine compensation for the land acquired. In 1861, due to unsatisfactory settlement and corruption the Act VI was amended and new law was put into effect where civil court had power to settle matters instead to arbitrators. 

In 1894, the Government of British India passed the Land Acquisition Act, 1894. This law gave the government the right to compel private landowners to sell their property or land to the government for public projects and the government assessed on the land’s purchase price. In 1948 the phrase “the whole of British India” was changed to “all the provinces to India.” 

The post-independence era had minor amendments made to the Land Acquisition Act, 1894. Wherein due to its notion of eminent domain the Bill of 2007 named Land Acquisition, Rehabilitation and resettlement Bill, 2007 was introduced. However, this bill lapsed in 2009 due to political opposition. As the result of this in 2013 enactment of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 (RFCT LAR&R Act, 2013) and in 2015 ordinance was introduced to alleviate implementation issues, but it remains stalled in parliament.

LEGISLATIVE FRAMEWORK

  1. The Land Acquisition Act, 1894. 

This Act comprises Eight (8) parts with Fifty-five (55) sections that laid down the powers and procedures for land acquisition including survey, notification, inquiry, hearings, and determination of compensation. Under section 3(f) of this Act defines “public purpose” where it includes provision of village-sites, town/rural planning, housing of poor and displaced persons, schools, corporation/offices and government sponsored educational, housing, health, and slum clearance scheme but does not include land acquisition.

The acquisition process starts with the Collector issuing a notice in the Official Gazette and two daily newspapers, followed by public notice put in the locations. Landowners were granted Thirty (30) days to file objections under section 5(a) of this Act. The compensation was determined based on the market value of the land at the time of the notification date issued, with improvements considered. However, the Act only provided Fifteen percent (15%) over the market value. 

This Act allowed both the central and state government to take immediate possession of the private property/land under section 17 (Special powers in cases of emergency), excluding all provisions except sections 5(a), 11 and 12. It required not to give a Fifteen days (15) notice. Many critics have criticized the Land Acquisition Act, 1894 for its vague definition of public purpose, and forced displacement without adequate rehabilitation. Despite minor amendments between 1956 to 2007, the act remained the sole legislation for land acquisition until 2013, expressing the doctrine of eminent domain and state sovereignty.

There are several problems when implemented, firstly, there is no clear basis as how the affected parties can be the definition is not precise. Usually only few of the landowners who are affected are identified. Secondly, the process of acquisition is time consuming that can take up to three years and lastly, there is no clear formula suggested or given as to how compensation must be calculated and the process of obtaining award from the courts are lengthy and in interim, due to which affected landowners are uncompensated and landless.

  1. The Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 (RFCT LAR&R 2013).

This Act replaced the Land Acquisition Act, 1894, it provides provision for land acquisition and as well as for rehabilitation and resettlement. According to this Act the process for land acquisition involves a Social Impact Assessment Survey which is a structured process to analyses, supervise and determine the positive and negative social consequences of a project, plan, and policy. Then a preliminary notification stating the intent for acquisition, a declaration of acquisition, and compensation to be given within 2 years after publication of declaration and is determined as of the date of notification. An additional 100% of the total compensation (market value + factor) is payable as solatium. This is an additional compensation to the market value. An additional 12% per annum is added to the market value from the date of SIA notification up to the date of award by the collector. 9% interest is levied from the date of taking possession until payment if not paid before taking such possession. If the delay exceeds 1 year, 15% per annum is payable on the unpaid portion.

In case of acquisition of land for the use by private companies or public private partnership, consent of Seventy percent (70%) of the displaced people will be required. Private companies that want to purchase a larger piece of land need to make sure or are required to comply with provision of rehabilitation and resettlement and must have Eighty percent (80%) consent of the affected families. The rehabilitation and resettlement program refer to the support provided to the families displaced by the land acquisition so that their livelihood can be rebuilt. While rehabilitation focuses on restoring economic and social well-being, resettlement involves providing alternative land, housing, or a location for relocation. 

The provisions of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 (RFCT LAR&R 2013) does not apply to acquisitions under Sixteen (16) existing legislation including the Special Economic Zones Act, 2005, the Atomic Energy Act, 1962, the Railways Act, 1989, etc.,

  1. The Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement (Amendment) Bill, 2015 (RFCT LAR&R 2015).

This Ordinance amends the Act passed in 2013. This Bill enables the government to exempt Five (5) categories of projects from the requirements of:

  1. social impact assessment, 
  2. restrictions on acquisition of multi-cropped land, and 
  3. consent for private projects and public private partnerships (PPPs) projects. 

The five categories of projects are: 

  1. defence, 
  2. rural infrastructure, 
  3. affordable housing, 
  4. industrial corridors, and 
  5. infrastructure including PPPs where the government owns the land.

This new Ordinance exempts all the five categories mentioned above from the provisions of the 2013 Act. This Ordinance also exempts any period if courts have given a stay on acquisition while computing Five (5) year period. It also requires a prior sanction to prosecute a government employee.

JUDICIAL PRECEDENTS

  1. Kedar Nath Yadav v. State of West Bengal, AIR 2016 SC 2434

Background:
The respondent purchased the Subject Land in the year 2001- 2002 with the objective of establishing a manufacturing facility for the production of ceramic electrical insulators. The Subject Land at the time was statedly an agricultural land. Land Reforms Officer, Hooghly, granted approval on 09-04-2003 for its conversion to industrial use, thereby enabling the formalization of commercial operations on the premises. Following the approval, the Respondent established a manufacturing unit, with necessary infrastructure, plant and machinery and commenced industrial operations. In 2006, after TATA Motors’ decision to establish its Tata Nano car manufacturing facility in Singur, Hooghly District, the Appellants had initiated acquisition that spanned over 1000 acres. On 21-07-2006 the Land Acquisition Collector, Hooghly (LAC), issued notifications under Section 4 of the Land Acquisition Act, 1894, initiating acquisition proceedings for the Tata Singur Project. The Respondent filed objections seeking exclusion of its operational manufacturing unit from the acquisition. The objections were rejected by LAC; the Appellants issued a declaration under Section 6 of the 1894 Act. After the declaration, the LAC passed the award for the Subject Land quantifying total compensation at INR 14,54,75,744, comprising INR 5,46,75,744 for land value and INR 9,08,00,000 for structures. The said compensation was duly deposited, and the Appellants thereafter took possession of the acquired land, which was thereupon handed over to TATA Motors. However, Tata’s Singur project was soon got into controversies generating widespread protests by affected farmers against displacement from their holdings. The acquisition, impacting fertile agricultural land, highlighted the tension between industrial development and farming communities. Eventually, the matter reached before the Supreme Court. Subsequently, in 2010, TATA Motors abandoned the Singur Project and withdrew from the site, with the Appellants regaining possession of the acquired land.

Issue:

Whether the land acquisition by the state was for a public purpose under Section 5A of the Land Acquisition Act, 1894?

Legal Provisions:

  1. Land Acquisition Act, 1894
  2. Section 4- Preliminary notification for acquisition
  3. Section 5-A- Right to object to acquisition
  4. Section 6- Declaration of intended acquisition
  5. Section 11- Award of compensation

Arguments

Appellants – The appellants argued that there was non-compliance with the mandatory procedures of the Land Acquisition Act, 1894. The land acquisition by the state was not for public purpose under section 3(f), and the Collector did not duly conduct an inquiry under section 5A. The declaration made under section 6 was without proper procedure. 

Respondents – Respondents argued that the land acquired was for a car manufacturing unit, which would create employment and would lead to socio-economic development.  The Collector made an award of compensation to the existing landowners. They further argued that the state has the right to acquire private property for public purpose (State’s eminent domain power).    

Judgment

The Supreme Court drew a distinction between the acquisition of land undertaken by the government for public purposes and for the companies. In this case, the Supreme Court quashed the acquisition on the grounds of violation of Section 5A procedures, non-compliance and failed to conduct a proper inquiry. Procedural defects in awarding compensation as awards were passed without following due process under Section 11 of the Act. The Court directed restoration of the land to the original owners and retain the compensation paid by government for acquisition.

  1. Kolkata Municipal Corporation & Anr v. Bimal Kumar Shah & Ors. (Civil Appeal No. 6466 of 2024)  

Background

The property at Premises No. 106C on Narikeldanga North Road in Kolkata was owned by Birinchi Bihari Shah. He inherited this property from his father. After attaining the age of majority, he was registered as the owner. In 2009, the Corporation attempted to unlawfully occupy the property, prompting Birinchi Shah to file a writ petition, which led to a High Court ruling that the Corporation must hold an enquiry into encroachments. In 2010, the Corporation unlawfully removed Shah’s name from property records and claimed ownership. This led Shah to contest the matter in court. The High Court ordered the Corporation not to interfere with Birinchi Bihari Shah’s property, as he was the real owner, as stated in an order on 8 January 2015. Later the Corporation claimed that they were acquiring the property to build a park under Section 352. The Single Judge did not find any legal reason for this. The Division Bench agreed with the Judge, leading the Corporation to appeal to the Supreme Court.

Issue

  1. Does Section 352 of the Kolkata Municipal Corporation Act, 1980, confer powers of compulsory acquisition? 
  2. Was KMC’s acquisition process in compliance with procedural safeguards mandated under Article 300A?

Legal Provisions 

Article 300A of the Constitution of India

Section 352 of the Kolkata Municipal Corporation Act, 1980 

Section 537 of the Kolkata Municipal Corporation Act, 1980 Land Acquisition Act, 1894 

Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 (RFCTLARR Act)

Arguments

Appellants- The appellants argued that Section 352 allowed the Kolkata Municipal Corporation to acquire the property for public purpose. The appellant stated that section 363 provided compensation for acquiring land under section 352. The appellant cited the cases of State of Kerala v. T.M. Peter and Girnar Traders v. State of Maharashtra, to argue that having different compensation do not violate equality rights under Article 14 of the Indian Constitution.

Respondents- The respondent argued that Section 352 lacked provisions that gave the power to acquire property from people, making the Kolkata Municipal Corporation’s actions illegal. The respondent stated that this procedure violated the constitutional guarantees under Article 300A.

Judgement 

The Court stated that Section 352 merely contemplates the power and duty of the Municipal Commissioner to identify the land intended for the opening of a street, park, etc., and once that decision is taken, the Municipal Commissioner would take steps to acquire such a property. Once the Municipal Commissioner takes the decision to acquire a piece of land, what would then be the process of acquisition is not provided in Section 352 but is provided under Section 535. The phrase ‘Municipal Commissioner may acquire’ in Section 352 is not at all the power of acquisition.

The Court further stated that when the Municipal Commissioner asks under Section 537 to get land for things like streets, squares and parks, the Government can start the process to get the land for the Corporation, such as those lands that are needed for the benefit of the public, as said in the Land Acquisition Act of 1894.

The Court said that under our constitutional scheme, compliance with a fair procedure of law before depriving any person of his immovable property is well entrenched. While it is true that after the 44th Constitutional Amendment, the right to property drifted from Part III to Part XII of the Constitution, there continues to be a potent safety net against arbitrary acquisitions, hasty decision-making and unfair redressal mechanisms. Despite its spatial placement, Article 300A has been characterised both as a constitutional and a human right. The Court remarked that “to assume that constitutional protection gets constricted to the mandate of a fair compensation would be a disingenuous reading of the text and, shall we say, offensive to the egalitarian spirit of the Constitution”.

Right to property – Broader and meaningful interpretation – Seven sub-rights

(1) The duty of the State to inform the person that it intends to acquire his property – the right to notice,

(i) The duty of the State to hear objections to the acquisition the right to be heard,

(ii) The duty of the State to inform the person of its decision to acquire the right to a reasoned decision,

(vi) The duty of the State to demonstrate that the acquisition is for public purpose the duty to acquire only for public purpose,

(v) The duty of the State to resituate and rehabilitate the right of restitution or fair compensation,

(vi) The duty of the State to conduct the process of acquisition efficiently and within prescribed timelines of the proceedings the right to an efficient and expeditious process, and

(vii) The final conclusion of the proceedings leading to vesting the right of conclusion.

COMPARITIVE ANALYSIS 

Basis of comparison 

Land Acquisition Act, 1894

RFCT LAR&R Act, 2013

RFCT LAR&R, 2015 

  1. Nature 

Colonial legislation expressed eminent domain and state sovereignty. 

Rights-based framework emphasised humane, participative, informed and transparent process. 

Proposed Amendments to 2013 Act, passed by Lok Sabha, and later lapsed. 

  1. Public Purpose

Section 3(f): Government schemes, offices, schools, housing for poor, rural planning and village sites were ambiguous and enabled arbitrary use. 

Section 2(1): Strategic purposes, defence, police, infrastructure, educational, health, tourism, housing. 

Same as 2013 but with exceptions. 

  1. Social Impact Assessment 

No Provision. 

Mandatory SIA. Assesses public purpose, affected families. 

Exempted 5 categories: Defence, rural infrastructure, affordable housing, industrial corridors, infrastructure.  

  1. Consent Requirement

No Provision.

80% for private companies and 70% for public-private partnership. 

Exempted 5 categories; no consent requirement. 

  1. Compensation 

Based on Market value 

Four times market value for rural areas and Two times market value for urban areas. 

Same as 2013 Act. 

  1. Solatium

30%

100%

100%

  1. Rehabilitation and Resettlement 

No Provision.

Necessary for all affected families. Minimum rehabilitation and resettlement entitlements to be provided to each family, with employment. 

R&R Award includes mandatory employment to at least one member of affected family of a farm labourer. 

  1. Food Security 

No Provision. 

Section 10 limits 5% of district agricultural land, multi-crop irrigated land to be acquired only at last resort. 

Exemption for 5 categories; no food security safeguards.

  1. Market Value

Based on the current usage of the land, prohibits using intended use of land while computing market value. 

Higher of: value specified for stamp duty and average of 50% by recorded price of sale of land. 

Same as 2013 Act. 

  1. Application to Kedar Nath Yadav v. State of West Bengal. 

The market value of the land was misclassified and was as low as 30% and the affected families were not provided with employment and shelter for their livelihood. 

Under this Act, the compensation is much higher than the1894 Act and employment and shelter will be provided to the affected families. 

Same as 2013 Act.

ANALYSIS

The shift from the Land Acquisition Act,1894, to the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 (RFCTLARR Act, 2013) represents a shift from a colonial, state-centric to participatory and rights-based Act. The categories exempted form SIA and consent requirements areas follows:

The National security and defense requirements 

  1. Rural infrastructure, including electrification and irrigation 
  2. Housing for the poor and affordable housing Industrial corridors,
  3. Infrastructure projects including PPP where land is owned by the government. 
  4. The 2013 Act stipulated that if compensation was not paid or possession was not taken within 5 years from the date of acquisition, the acquisition process shall lapse. This amendment provided that if the delay was due to court or landowner litigation or the period stipulated by the tribunal to take possession, it would not be included in the 5 years.
  5. This amendment also stated that no action shall be taken without prior government sanction to prosecute the government officials.
  6. Under the new proposed bill of 2015, at least one member of the affected families will get employment under rehabilitation and resettlement award.

RECOMMENDATIONS

  1. Legislative Balance: The law must ensure exemptions under the 2013 and proposed bill of 2015 do not harm affected families and vulnerable cultivators.
  2. Procedure: All land acquisition must comply with 7 sub-rights of Article 300A.
  3. Simplify the SIA process: So that the intended public purpose can be achieved, while maintaining community participation and its protective nature.  
  4. Land pooling: Instead of the traditional land acquisition, it could be beneficial to both the land owner and the acquirer. A successful example of land pooling can be observed in Gujarat (Town Planning Schemes) and Andhra Pradesh (Amaravati Land Pooling Scheme)
  5. Land leasing: It can also be an alternative to land acquisition, benefiting the landowners by receiving regular rental income or profit-sharing benefits.
  6. Monitoring: To track implementations of the Act across all the states, publish annual reports. 

CONCLUSION

The comparative study of land acquisition frameworks in India from 1894 to 2013 to 2015 reveals a revolutionary trajectory from colonial state sovereignty to rights-based governance embodying justice, participation, transparency, and human dignity. The Land Acquisition Act 1894 was the representation of the doctrine of eminent domain with little safety, undefined public purpose, inadequate compensation and no rehabilitation that led to arbitrary usage and forced displacement of vulnerable agricultural workers. Tata Nano Project’s land acquisition case indicated the reason of failure 

The RFCTLARR Act, 2013 marks a historic shift with the introduction of Social Impact Assessment, compulsory consent (80% private, 70% PPP), improved compensation, rehabilitation and resettlement entitlements and food security protection. While the 2015 Amendment Bill tries to address problems of implementation, it carries substantial danger by excluding 5 classes from SIA, consent and food security protection, widening its ambit from “company” to “entity.” Precedents such as Kedar Nath Yadav (2016) and Kolkata Municipal Corporation (2024) have made the first clear difference between “public purpose” and “interest of the company” and laid down 7 procedural sub-rights under Article 300A. The study concludes that while infrastructure development is essential for national growth, legislation must strike a balance to ensure the welfare of the people through procedural due process, fair compensation and rehabilitation and resettlement

REFERENCES

  1. The Land Acquisition Act, 1894 (Act 1 of 1894)
  2. The Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and
    Resettlement Act, 2013 (Central Act 30 of 2013)
  3. The Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement (Second Amendment) Bill, 2015
  4. PPRC (2015) ‘Land Acquisition: The Act, The Ordinance and The Bill’, PPRC, June, Available at: https://www.pprc.in/upload/Land%20AcqUnderstanding%20Amendments_JUNE2015.pdf  
  5. PPRC (2015) ‘Land Acquisition: The Act, The Ordinance and The Bill’, PPRC, June, Available at: https://www.pprc.in/upload/Land%20AcqUnderstanding%20Amendments_JUNE2015.pdf  
  6. PPRC (2015) ‘Land Acquisition: The Act, The Ordinance and The Bill’, PPRC, June, Available at: https://www.pprc.in/upload/Land%20AcqUnderstanding%20Amendments_JUNE2015.pdf  
  7. PRS India (2015) ‘Summary of the LARR (Amendment) Ordinance, 2015’, PRS India, Available at: https://prsindia.org/files/bills_acts/bills_parliament/2015/Summary_LARR_(A)_Ordinance_2015_1.pdf 
  8. REFWORLD (2024) ‘India: Right to Fair Compensation and Transparency in Land Acquisition and Resettlement Bill, Amendment Ordinance (2015)’, REFWORLD, 9 February, Available at: https://www.refworld.org/legal/legislation/natlegbod/2015/en/121318   
  9. SCC Online (2025) ‘SC on Tata Motors’ Singur Land Acquisition’, SCC Times, 27 October, Available at: https://www.scconline.com/blog/post/2025/10/28/supreme-court-tata-motors-singur-land-restoration-for-industrial-entity/  
  10. Social Protection & Human Rights (2016) ‘Kedar Nath Yadav v. State of West Bengal & Others Archives’, Social Protection & Human Rights, 31 January, Available at: https://socialprotection-humanrights.org/case/kedar-nath-yadav-v-state-of-west-bengal-others/  
  11. Supreme Court Observer (2025) ‘SCO.LR | 2025 | Volume 10 | Issue 3’, Supreme Court Observer Law Reports, 19 October, Available at: https://www.scobserver.in/journal/sco-lr-2025-volume-10-issue-3/  
  12. Supreme Court Observer (2025) ‘Parties Dormant during Litigation Cannot Claim Benefits Secured by Judicial Order’, Supreme Court Observer, 19 October, Available at: https://www.scobserver.in/supreme-court-observer-law-reports-scolr/parties-dormant-during-litigation-cannot-claim-benefits-secur  
  13. ‘The Land Acquisition Act, 1894 & 2013: A Comparative Study’, International Journal of Legal, Medical & Health Sciences, Available at: https://ijlmh.com/paper/the-land-acquisition-act-1894-2013-a-comparative-study/?pdf=1 
  14. ResearchGate (2015) ‘Comparative Analysis of Land Acquisition Acts in India: Case Based Approach’, ResearchGate Publications, Available at: https://www.researchgate.net/publication/281062269_Comparative_analysis_of_Land_acquisition_acts_in_India_Case_based_approach  
  15. Law Journals (2025) ‘The Shift from the Land Acquisition Act, 1894, to the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013: A Comparative Study’, Law Journals, Vol. 11, No. 11, pp. 11268, Available at: https://www.lawjournals.org/assets/archives/2025/vol11issue11/11268.pdf  
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