The Supreme Court held that the Madhya Pradesh Special Police Establishment of the Lokayukt Organisation — which investigates corruption under the Prevention of Corruption Act and IPC sections 409, 420 and Chapter XVIII — is not an 'intelligence and security' organisation within Section 24(4) of the Right to Information Act, 2005, and struck down the State notification exempting it. It also held that a court may test the vires of subordinate legislation suo motu once the issue squarely arises and the State is heard.
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.
On 6 March 2020, a five-judge Constitution Bench overruled *Pune Municipal Corporation v. Harakchand Misirimal Solanki* (2014) and substantially restructured the doctrinal architecture under Section 24(2) of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013. The substantive reading: 'or' between possession and compensation in Section 24(2) is to be read as 'nor' — the deemed lapse of acquisition proceedings requires that both conditions be unmet, not just one. A digest of the holding, the doctrinal architecture, and the substantive implications for land-acquisition practice.