Legality of de-licensing and re-licensing of land under the urban development framework

The power to grant a license under the Haryana Development and Regulation of Urban Areas Act, 1975, inherently carries with it the power to modify, vary, or de-licence land in accordance with statutory provisions and the General Clauses Act. State planning authorities possess the requisite administrative competence to permit the bifurcation of a licensed area into residential and commercial components based on evolving master plans and topographical requirements. The subsequent enactment of the 2020 Amendment inserting Section 3(3A) into the statute provides explicit legislative backing and retrospective validation to such de-licensing actions undertaken in good faith. Consequently, the executive action of de-licensing a portion of land originally earmarked for group housing and re-licensing it for commercial use in a designated special zone is legally sound, valid, and fully supported by statutory authority. (Raj Singh Gehlot & Ors. v. Amitabha Sen & Ors. | 2026 INSC 77)