Kamla Nehru Memorial Trust v. UPSIDC: Supreme Court Upholds Public Trust Doctrine in Land Allotment
The Supreme Court upheld cancellation of industrial land allotment, reaffirming the Public Trust Doctrine in matters of public resource allocation.
Adv. Rajesh Kumar
Senior Partner, Real Estate Law

Introduction
In Kamla Nehru Memorial Trust & Anr. v. U.P. State Industrial Development Corporation Ltd. & Ors. (2025 INSC 791), the Supreme Court reaffirmed the Public Trust Doctrine in matters concerning allocation of public resources.
Background
The case involved cancellation of an industrial land allotment originally granted to Kamla Nehru Memorial Trust by UPSIDC due to alleged violations of allotment conditions.
Key Holdings
- Public Trust Doctrine: Public resources must be allocated in public interest with procedural propriety
- Contractual Obligations: Allottees must strictly comply with allotment conditions
- State's Power: State can cancel allotments for violation of conditions
The Public Trust Doctrine
The Court emphasized that public land is held by the State as trustee for the public. Allocation must serve public interest and any deviation justifies cancellation.
Implications for Developers
Developers and institutions receiving government land allotments must strictly adhere to allotment conditions or face cancellation without compensation.
Legal Disclaimer
This article is for informational purposes only and does not constitute legal advice. The information contained herein may not be applicable to all situations and may not reflect the most current legal developments. Please consult with a qualified attorney for specific legal advice regarding your situation.