The Supreme Court ruled that the government cannot use summary eviction powers to dispossess a person when a genuine title dispute exists over the property. Invoking Article 300A, the Court held that deprivation of property requires authority of law, and administrative eviction without adjudicating ownership bypasses that constitutional guarantee. The ruling reinforces that property rights, even post-44th Amendment, carry procedural protections that the State cannot sidestep through executive action alone.

Article 300A, inserted by the 44th Constitutional Amendment in 1978, removed the right to property from the fundamental rights chapter (formerly Article 19(1)(f) and Article 31) and relocated it as a constitutional right. The amendment means property can no longer be enforced via writ under Article 32, but the State still cannot deprive a person of property without authority of law.

The Supreme Court has progressively expanded Article 300A's content. In Vidya Devi v. State of H.P. (2020), the Court held that even the State cannot take property without following due process and paying compensation. In Kolkata Municipal Corporation v. Bimal Kumar Shah (2024), the Court identified seven distinct rights within Article 300A: the right to notice, hearing, a reasoned order, natural justice, the right not to be treated arbitrarily, the right to compensation, and an efficient and speedy dispute resolution process.

This ruling adds a critical procedural layer: where the occupant raises a bona fide title dispute, the government must get that dispute adjudicated before resorting to eviction. Summary eviction — an executive action taken without a civil court determination of title — violates Article 300A because deprivation of property must occur only through a valid legal process, not administrative shortcut.

The test the Court applied: (1) Does a genuine title dispute exist? (2) Has that dispute been adjudicated by a competent forum? If yes to the first and no to the second, summary eviction is constitutionally impermissible. This prevents the State from using its coercive power to pre-empt civil title litigation.