Supreme Court Clears Way for Dharavi Residents’ Rehabilitation on Mulund Salt Pan Land

August 30, 2025

Introduction

In a landmark decision that could reshape Mumbai’s urban planning, the Supreme Court of India has upheld the Bombay High Court’s ruling to allocate 150 acres of Mulund salt pan land for the rehabilitation of ineligible Dharavi residents under the Dharavi Redevelopment Project (DRP). The verdict brings closure to a decades-long legal dispute over land originally leased for salt production but left unused for over 30 years.

Dharavi Redevelopment Project: Eligibility Criteria

The Dharavi Redevelopment Project, one of the world’s largest urban renewal initiatives, classifies residents into categories based on settlement dates:

Residents before January 1, 2000: Eligible for free 350 sq ft homes within Dharavi.
Residents between January 1, 2000 and January 1, 2011: Eligible for 300 sq ft homes at alternate sites, such as the Mulund salt pan land.

This classification ensures equitable rehabilitation while addressing the housing needs of a massive slum population.

The Land Lease History: From Colonial-Era Agreements to Modern Dispute

The controversy over this land dates back over a century.

In 1921, the Secretary of State for India executed three lease deeds granting 782 acres of salt pan land in Mulund, Bhandup, and Kanjurmarg exclusively for salt production.
The 99-year lease, effective from 1917, was later transferred to Vikas Walawalkar in 1994 as a sub-lessee through a supplementary agreement.
The lease expired in October 2016, triggering legal battles over renewal rights and land use.

The Legal Battle: Claims and Counterclaims

Walawalkar argued that salt production stopped due to uncontrolled encroachments by slums and industries discharging sewage into the salt pans, making operations impossible. He sought a renewed 99-year lease and protection over the land.
However, authorities contended that the land had been grossly underutilized for decades, violating lease terms.

Bombay High Court’s Stand

In August 2023, Justice Sandeep Marne upheld the lease termination, stressing:

“In a city like Mumbai, where land prices are among the highest in the country, permitting the use of 782 acres of land for salt manufacturing cannot be confused with creating any vested rights in favor of the lessee.”

The court ruled that land use rights do not translate into ownership rights.

In April 2024, a division bench led by Justices BP Colabawalla and Firdosh Pooniwalla partially allowed Walawalkar to retain 632 acres east of the Eastern Express Highway—on condition of continued assignment fee payments. However, the 150 acres west of the highway were excluded, citing over three decades of inactivity.

Supreme Court’s Final Verdict

On August 20, 2025, a Supreme Court bench comprising Justices Arvind Kumar and NV Anjaria dismissed Walawalkar’s appeal.
The Court noted:

“Out of the total extent of 782.46 acres, 150 acres was not utilised for the purpose for which it was leased for almost 30 years.”

This judgment effectively cleared the way for the Maharashtra government to use this land for rehabilitating Dharavi’s ineligible residents, aligning with the state’s housing policy.

Local Opposition in Mulund

While the decision is hailed as a victory for urban renewal, Mulund residents have raised objections, citing:

Strain on civic infrastructure such as roads, water supply, and sewage systems.
Demographic concerns over the large-scale relocation of families.

This tension highlights the challenges of balancing development needs with local interests in a city with one of the highest real estate pressures in the world.

Implications for Mumbai’s Urban Landscape

This ruling is a significant step for the Dharavi Redevelopment Project, which has often been delayed due to legal disputes and land acquisition challenges. The Supreme Court’s verdict reinforces:

Judicial support for equitable housing policies over private claims.
The principle that unused public land cannot be held indefinitely under defunct leases.
A pathway for unlocking land parcels in a land-starved city like Mumbai for large-scale rehabilitation.

Conclusion

The Supreme Court’s decision to release 150 acres of Mulund salt pan land underscores the judiciary’s role in balancing individual leaseholder rights with public interest and urban development goals. For Mumbai, this marks another step toward transforming Dharavi’s living conditions while also setting a precedent for similar disputes over underutilized land in metropolitan areas.

As Mumbai continues to grow, this ruling could become a model for reimagining city spaces and prioritizing affordable housing over outdated industrial leases.