Under the Land Acquisition Act, 1894, does an order quashing acquisition proceedings benefit persons who were never parties to the challenge?

Not ordinarily. Orders quashing acquisition may operate either in personam or in rem. Where the Court quashes acquisition on grounds personal to individual objectors, such as vitiated consideration of their own objections under Section 5-A, the relief operates in personam and benefits only those who contested the matter. The benefits accrue to non-parties only where the entire acquisition has been struck down as void ab initio on fundamental grounds applicable to all.

Land Acquisition Act, 1894 — s.4 — s.5-A — s.6 — s.11 — Quashing of acquisition proceedings — Restoration of land — Relief in personam and in rem — Objections not pursued — Waiver — Delay and acceptance of compensation — Public Interest Litigation — Land Acquisition Act, 1894 — Restoration remedy — Intended beneficiaries — Held: A restoration remedy grounded in the structural incapacity of poor agricultural workers to resist the State does not extend to a commercial enterprise possessing financial capacity and institutional sophistication. The reasoning does not enure to its benefit. (¶15, 18) Land Acquisition Act, 1894 — s.5-A — Quashing order — In personam or in rem — Held further: Where acquisition is quashed on grounds personal to individual objectors, the relief operates in personam and benefits only those who contested before judicial forums. Only a declaration that the entire process is void ab initio operates in rem. (¶19) Land Acquisition Act, 1894 — s.5-A — Objections filed but not pursued — Waiver — Held further: Objections under Section 5-A raise issues personal to each landowner, and mere filing does not exhaust the remedies available in law. Where they are not pursued through litigation, the notification becomes conclusive proof of waiver. (¶20) Land Acquisition Act, 1894 — Delay — Compensation accepted without protest — Parity refused — Held further: A claimant silent for a decade, who accepted the award without protest while others litigated, cannot seek parity with them. Permitting it would reward strategic inaction and passive opportunism. Appeal allowed. (¶21, 22, 26)

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