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Bombay HC Greenlights LARR Authority's Power to Probe Limitation in Bullet Train Land Row
In a significant ruling for land acquisition disputes, the has affirmed that the holds jurisdiction to examine limitation periods in compensation reference proceedings under the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013. The division bench of Justice Manish Pitale (writing the order) and Justice Shreeram V. Shirsat dismissed two writ petitions filed by , upholding LARR orders that set aside an ex-parte directive, condoned delays in filing written statements, and permitted amendments to include limitation pleas.
This decision, pronounced on April 24, 2026, in Godrej & Boyce Mfg. Co. Ltd. vs. & Ors. (WP Nos. 12027/2025 & 3467/2026), clarifies procedural flexibilities in high-value land claims, particularly amid India's infrastructure push like the Mumbai-Ahmedabad Bullet Train project.
Godrej's Vikhroli Land Grabbed for High-Speed Rails
The saga began with the acquisition of Godrej's 10-acre plot in Vikhroli, Mumbai Suburban, for the project. An award dated September 15, 2022, by the Deputy Collector (LA) No.7 fixed compensation, prompting Godrej's failed challenge via writ petition (dismissed February 9, 2023) and SLP (dismissed February 24, 2023). The apex court directed swift disposal of any reference for enhanced compensation.
Godrej filed a reference under Section 64 on February 28, 2023, seeking hikes from Rs. 572 crores (initial claim, boosted via amendments to Rs. 1,972 crores backed by valuer reports). Delays ensued: LARR initially lacked jurisdiction to nudge the Collector, resolved by a September 2023 Bombay HC order. The reference reached LARR (Aurangabad, later Nashik) in October 2023.
Respondents—Collector and Deputy Collector—skipped nine hearings, leading to an ex-parte order on March 15, 2024. NHSRCL filed its reply but later sought amendment for limitation. In April 2025, all respondents moved applications, culminating in the challenged LARR orders: one on August 21, 2025 (setting aside ex-parte, condoning delay), and February 18, 2026 (NHSRCL amendment).
Petitioner's Plea: Too Late, Too Prejudicial
Godrej argued the respondents' chronic absenteeism derailed proceedings, with a December 2024 letter from Deputy Collector treating the award as their "written statement." Allowing belated filings prejudiced Godrej, especially post two claim amendments. Limitation jurisdiction rests solely with the Collector (executive function under Section 64), per Deputy Commissioner vs. S.V. Global Mill Ltd. (2026 SCC OnLine SC 171) and Bombay HC's Hirabai Sonu Wanjari (2026). Reference proceedings aren't suits ( Kamalabai Bhaskar Mule , 2021(1) MhLJ 521), and no delay existed given litigation pauses ( Manharlal Shivlal Panchal , 2022 SCC OnLine SC 1707).
Respondents' Counter: Justice Demands Flexibility
The State cited nascent institutional mechanisms for LARR representation, voluminous records needing coordination, and no prejudice—Godrej amended claims thrice, ballooning demands. NHSRCL invoked liberal amendment norms for written statements ( B.K. Narayana Pillai , (2000)1 SCC 712; LIC vs. Sanjeev Builders , (2022)16 SCC 1). LARR, as reference court successor, can probe limitation ( Mohammed Hasnuddin vs. State of Maharashtra , (1979)2 SCC 572; Bombay HC's Shantaram Ganesh Shenoy , 2006 SCC OnLine Bom 314). Collector's September 25, 2023 order ambiguously noted delay.
Court's Sharp Reasoning: No Jurisdictional Blind Spot
Dismissing hyper-technical bars, the bench noted LARR's discretion in original proceedings outweighed writ interference. Sufficient cause for State delay—delayed counsel appointment—was established ( G.P. Srivastava vs. R.K. Raizada , (2000)3 SCC 54). Godrej's amendments justified reciprocity.
Crucially, rejecting Godrej's narrow read of precedents, the court held: LARR mirrors the old reference court, wielding inherent power over limitation as it
"goes to the very root"
of jurisdiction. Excluding it would create anomalies, allowing higher courts to decide but not LARR itself. The Collector's order lacked explicit condonation, flagged by reference forms, warranting LARR scrutiny. Amendments cause "no prejudice," with merits pending.
Legal reports echo this: the Bombay HC observed LARR
"exercises powers akin to the reference court,"
necessarily covering limitation (as in provided summaries).
Key Observations
"It would be illogical to hold that while the LARR Authority has the jurisdiction to decide the reference on the question of enhancement of compensation on merits, it does not have jurisdiction to decide the question of limitation."
"The issue of limitation can be raised at any point of time as it impinges upon the very exercise of jurisdiction."
"Considering the fact that [reference proceedings] are original proceedings and in the light of the reference of the petitioner being amended on two occasions, no prejudice is caused to the petitioner if the written statement... has been taken on record."
Petitions Tossed: Fast-Track to LARR Finale
Writs dismissed; stays vacated. LARR Nashik directed to decide reference expeditiously (within six months). This bolsters procedural equity in acquisitions, empowering LARR on threshold issues while signaling leniency for public entities. For claimants like Godrej, it underscores contesting limitations head-on; for projects like bullet trains, smoother references amid rising claims.
Landowners and developers watch: does this tilt scales toward fuller hearings, or prolong battles over technicalities?
