Environmental Foundation Ltd. v. The Land Commissioner and Others – sllr 1993 volume 2 page 041

In the case between Environmental Foundation Ltd. (petitioner) and the Land Commissioner, the Minister of Lands, Irrigation and Mahaweli Development, and Aitken Spence Hotel Management (Pvt.) Ltd. (respondents), the issue concerned whether the process of leasing Crown Land under Regulation 21(2) of the Crown Lands Ordinance required mandatory public notification in the Gazette. The court held that a prima facie case was established for the necessity of such a notification, reaffirming the principle that procedural requirements contained in statutory regulations governing state land must be strictly complied with to uphold the validity of administrative actions. Reliance was placed on the Crown Lands Ordinance and the Interpretation Ordinance, emphasizing that the statutory framework and es