Dalsukbhai Bachubhai Satasia v. State of Gujarat & Others; 2026 INSC 21 - Urban Land (Ceiling and Regulation) Act
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Urban Land (Ceiling and Regulation) Act, 1976- The requirement of issuance of notice under Section 10(5) is mandatory and must be issued to the person(s) actually in possession of the concerned land. (Para 18) - The land ‘vesting’ with the State Government does not connote the transfer of possession. Rather, what is ‘deemed’ to have ‘vested’ are the aspects that have deemed i.e., by a legal fiction to have been ‘acquired’, i.e., title or interests. Possession, as explained in Hari Ram vests de jure and not de facto. ‘Acquisition’ (of title or interests) does not necessarily involve the transfer of such de facto possession. Such transfer requires certain explicit steps to be taken fter de jure possession is vested, there are three methods by which de facto possession may be transferred: the first is voluntary transfer by the possessor under Section 10(3) of the ULC Act. If possession is not voluntarily transferred, then the second method is through delivery of notice under Section 10(5) of 29 the ULC Act to the possessor. In case possession is still not transferred, then the third method involves the Competent Authority taking possession under Section 10(6) of the ULC Act (by force, if required) and delivering it to the State Government. (Para 17)
Case Info
Dalsukbhai Bachubhai Satasia & Others v. State of Gujarat & Others; 2026 INSC 21.
Case Details
- Case name: Dalsukbhai Bachubhai Satasia & Others v. State of Gujarat & Others.
- Neutral citation: 2026 INSC 21.
- Coram: B.V. Nagarathna, J.; R. Mahadevan, J.
- Judgment date: January 06, 2026.
Caselaws and Citations
- State of Uttar Pradesh v. Hari Ram, (2013) 4 SCC 280.
- C. Albert Morris v. K. Chandrasekaran, (2006) 1 SCC 228.
- State of Assam v. Bhaskar Jyoti Sarma, (2015) 5 SCC 321.
- Mangalsen v. State of Uttar Pradesh, (2014) 15 SCC 332.
- Gajanan Kamlya Patil v. Additional Collector & Competent Authority, (2014) 12 SCC 523.
- U.A. Basheer v. State of Karnataka, (2021) 5 SCC 313.
- State of Orissa v. Sakhi Bewa, (2022) 16 SCC 594.
- AP Electrical Equipment Corporation v. Tahsildar, 2025 SCC OnLine SC 447.
Statutes/Laws Referred
- Urban Land (Ceiling and Regulation) Act, 1976:
- Sections 2(1), 5(3), 6(1), 8(4), 9, 10(1)–10(6), 11, 14, 20(1), 21, 23, 27, 33, 34.
- Urban Land (Ceiling and Regulation) Repeal Act, 1999:
- Sections 3 (Savings) and 4 (Abatement of legal proceedings).
- Gujarat Land Revenue Rules, 1972:
- Rule 108(6A).
- Cantonments Act, 1924:
- Section 3 (referenced in Explanation to Section 10 ULC Act).
