Madras High Court Flags Unjust Enrichment in ₹1 Public Land Lease Case

The Madras High Court permitted SIPCOT to recover sub-leasing charges from a private firm that had leased 17.64 acres of public industrial land for ₹1 per year but was earning over ₹12.4 lakh monthly by sub-letting it.

Setting aside a 2022 single-judge order, the Bench held that such arrangements amount to “unjust enrichment” and are opposed to public policy.

The Court ruled that buildings constructed on leased land are inseparable from it, making sub-leasing of sheds effectively sub-letting of land.

Invoking Article 39(b) and (c) and the public trust doctrine, the Court stressed that public resources cannot be exploited for disproportionate private gain.

[Spicot v. Carriers]