1. Under the scheme of the Land Acquisition Act, 1894 and the 2013 Act, once the land vests in the State Government after the passing of an award and taking of possession, it vests free from all encumbrances. As observed in Indore Development Authority (supra), there is no provision denuding title which has vested in the beneficiary corporation or transferring title to subsequent purchasers.
2. The legal fiction of deemed lapse under Section 24(2) of the LARR Act, 2013 cannot be extended to denude title in the beneficiary or subsequent transferees if possession was taken or compensation was deposited.
3. A subsequent transferee of acquired land has no locus standi to challenge the acquisition proceedings, as the transfer itself is a nullity void ab initio in respect of encumbrances on government land. Their only potential remedy would be to claim compensation for the interest surrendered, which has not been established here.
4. Irregularities in the notification of change of user or lack of local publication under the West Bengal Land (Development and Planning) Act, 1948 are not valid grounds to quash an otherwise completed and valid acquisition where the land has already vested in the State.
5. Possession taken after the award is sufficient for vesting under Section 16 of the 1894 Act; it does not require non-deposit of compensation, though increased interest follows the failure to pay.
6. An acquisition proceeding initiated under Section 4 and declared under Section 6 of the 1948 Act becomes subject to the 1894 Act under Section 8 upon the declaration. Once possession is taken and award made with apportionment, the proceedings are complete and have not lapsed.
7. Appeals filed by specific government departments or acquirers like KMDA and private entities like KIL as beneficiaries are maintainable under Section 3(b)/3(d) of the Land Acquisition Act to protect the title they seek to acquire, superseding older precedents excluding such beneficiaries from appeal rights.
