Manalapan Holding Co. v. Planning Bd. of the Township of Hamilton

In Manalapan Holding Co. v. Planning Bd. of the Township of Hamilton, 92 N.J. 466, 457 A.2d 441 (1983), the Hamilton Planning Board claimed the right to defer decision on a preliminary subdivision application pending county approval. This position was unanimously rejected by the Supreme Court of New Jersey which held, pursuant to N.J.S.A. 40:55D-48(c), that a Board must act within the statutory time period, and may not defer decision pending resolution of those development issues within the County's jurisdiction, or for any other reason, if the effect of that deferral is to unilaterally extend the statutory time period for granting or denying a development application. Id. at 478, 457 A.2d 441.