On 24 November 2020, a two-judge Bench of the Supreme Court held that the Union's continued occupation of requisitioned land for 33 years after its requisitioning authority had lapsed was 'condoning lawlessness'. Justice S. Ravindra Bhat's judgment read Article 300A as standing on the same footing as Articles 21 and 265 — a guarantee of the supremacy of the rule of law — and directed possession to be restored within three months. The case turns on the distinction between requisition and acquisition.
On 10 February 1970, an eleven-judge Constitution Bench of the Supreme Court struck down the Banking Companies (Acquisition and Transfer of Undertakings) Act, 1969 by a ten-to-one majority. Justice J.C. Shah's majority judgment did three doctrinally distinct things: it read Article 31(2) compensation as a 'just equivalent', it replaced the object/subject test with an effect test, and it overruled A.K. Gopalan's silo theory of fundamental rights — the analytical move that, eight years later, made the golden triangle of Maneka Gandhi possible.