Facts: The petitioners are landowners whose lands were taken into possession by the respondent authorities on 2 February 1996 for the construction of a Village Tank in Beed district. Possession was taken via private negotiation, and the project was completed that same year. Despite three decades passing and the project being in full operation, the State failed to complete the formal land acquisition process or pay compensation. Although an award was finally declared on 23 November 2020—only after the landowners previously approached the High Court—no notice of the award was served, and no compensation or statutory interest was paid. The State's primary excuse for non-payment was the lack of receipt of funds from the proposing department.
Procedural Posture: The petitioners filed a Writ Petition under Article 226 of the Constitution of India before the Bombay High Court (Aurangabad Bench), seeking a mandamus to compel the State to complete the acquisition proceedings and pay the awarded compensation along with statutory interest.
Issue: Whether the prolonged failure of the State to pay compensation for land taken in 1996 constitutes a violation of Article 300A of the Constitution, and whether the Court can issue systemic, time-bound directions to address widespread administrative lapses in land acquisition matters.
Holding: Yes. The Court held that the State cannot plead administrative inefficiency or inter-departmental delays as a defense for violating constitutional guarantees. The State was directed to pay compensation with interest within eight weeks and establish a statewide, mission-mode mechanism to resolve all similar pending cases.
Reasoning: The Court reasoned that Article 300A mandates that no person shall be deprived of property save by "authority of law", which necessarily includes the lawful determination and prompt payment of compensation. Acquisition without payment due to administrative lapse is a continuing wrong and a breach of constitutional duty. The Court observed a systemic failure where the State's negligence caused "multi-dimensional consequences", including manifest hardship to citizens and an avoidable financial burden on the exchequer due to escalating interest rates. Invoking its powers under Article 226, the Court adopted the mechanism of "continuing mandamus" to ensure accountability and commanded the Chief Secretary to oversee a comprehensive identification and resolution of all such pending acquisition cases across Maharashtra.