In May 2024, a three-judge bench applied Indore Development Authority v. Manoharlal to hold that deemed lapse under Section 24(2) requires both non-payment and non-possession, upheld the Delhi acquisitions, and held that a subsequent change in the law is no ground for condonation of delay.
In 2013 the Supreme Court consolidated the scattered principles governing condonation of delay under Section 5 of the Limitation Act into a single authoritative set of propositions — the standard checklist on what counts as sufficient cause.