Section applies to lease of air space above land used by a public utility, and approval of commission must be obtained. 54 H. 402, 507 P.2d 755.

PUC did not fail to protect public interest with regard to HECO's contract for purchase of land in Heeia Kea. 64 H. 289, 639 P.2d 1103.

Unsecured obligation to make payments in future is not an encumbrance. 64 H. 289, 639 P.2d 1103.

Cited: 178 F. Supp. 637, 640.