1. Land acquisition — Compensation determined via voluntary agreement under Section 7(2) of the Tamil Nadu Acquisition of Land for Industrial Purposes Act, 1997 — Dispute over statutory interest. (Para 9 , 10 , 11 , 13 , 14 , 15 )
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2025 Supreme(SC) 1949
SUPREME COURT OF INDIA
M. M. SUNDRESH, NONGMEIKAPAM KOTISWAR SINGH, JJ.
The Government Of Tamil Nadu, Rep. By Its Secretary, Transport Department & Ors. – Appellants
Versus
P.R. Jaganathan & Ors Etc. – Respondents
Civil Appeal No. 13839-13852 of 2025 (Arising out of SLP (C) Nos. 12770-12783 of 2020)
Decided On : 19-11-2025
Advocates appeared:
For the Petitioner(s): Mr. Balaji Subramaniam, AAG/Adv. Ms. G. Indira, AOR Mr. P Gandepan, Adv. Mr. Akash Kundu, Adv. Ms. Anjali Singh, Adv. Ms. Raniba Pangnila, Adv. Ms. Amrit Kaur, Adv. Mr. Anurag Kashyap, Adv. Mr. D.Kumanan, AOR
For the Respondent(s): Mr. Ashwarya Sinha, AOR Ms. Surbhi Kumari, Adv. Mr. Aditya Malhotra, Adv. Mr. Sankalp Mahindru, Adv. Mr. S. Gowthaman, AOR Mr. S. Nagamuthu, Sr. Adv.(NP) Mr. C. Paramasivam, Adv. Mr. M.p. Parthiban, AOR Ms. Priyaranjani Nagamuthu, Adv. Ms. Shalini Mishra, Adv. Mr. Bilal Mansoor, Adv. Mr. Shreyas Kaushal, Adv. Mr. S. Geyolin Selvam, Adv. Mr. Alagiri K, Adv. Mr. Shivansh Sharma, Adv. Mr. Rohan Singh, Adv. Mr. Abhishek S, Adv. Mr. Saurabh Jain, Adv. Mr. Prayag Jain, Adv. Mr. Kaushik Poddar, AOR Mr. Rajinder Singh, AOR Mr. R Sharath, Adv. Mr. Arjun Sharma, Adv.
For the Petitioner(s): Mr. Balaji Subramaniam, AAG/Adv. Ms. G. Indira, AOR Mr. P Gandepan, Adv. Mr. Akash Kundu, Adv. Ms. Anjali Singh, Adv. Ms. Raniba Pangnila, Adv. Ms. Amrit Kaur, Adv. Mr. Anurag Kashyap, Adv. Mr. D.Kumanan, AOR
For the Respondent(s): Mr. Ashwarya Sinha, AOR Ms. Surbhi Kumari, Adv. Mr. Aditya Malhotra, Adv. Mr. Sankalp Mahindru, Adv. Mr. S. Gowthaman, AOR Mr. S. Nagamuthu, Sr. Adv.(NP) Mr. C. Paramasivam, Adv. Mr. M.p. Parthiban, AOR Ms. Priyaranjani Nagamuthu, Adv. Ms. Shalini Mishra, Adv. Mr. Bilal Mansoor, Adv. Mr. Shreyas Kaushal, Adv. Mr. S. Geyolin Selvam, Adv. Mr. Alagiri K, Adv. Mr. Shivansh Sharma, Adv. Mr. Rohan Singh, Adv. Mr. Abhishek S, Adv. Mr. Saurabh Jain, Adv. Mr. Prayag Jain, Adv. Mr. Kaushik Poddar, AOR Mr. Rajinder Singh, AOR Mr. R Sharath, Adv. Mr. Arjun Sharma, Adv.
A concluded contract under the Tamil Nadu Acquisition of Land for Industrial Purposes Act excludes claims for additional relief such as interest once an agreement on compensation has been reached.
Headnote:(A) The Tamil Nadu Acquisition of Land for Industrial Purposes Act, 1997 - Sections 7 and 12 - The Court addressed whether a party to a concluded contract can seek further relief under statutory provisions. The judgment emphasized the sanctity of agreements made under Section 7(2) and determined that, once an agreement is reached, interests cannot be claimed under Section 12 of the Act - The essence of the agreement has to govern the parties involved and excludes recourse to statutory provisions post-agreement. (Paras 5-24)
Facts of the case:
The dispute arose from lease agreements dating back to 1942 and subsequent acquisition proceedings initiated for expansion of an airport, where compensation negotiations occurred as per the 1997 Act.
Findings of Court:
The Court found that the High Court incorrectly applied Section 12 of the Act regarding interest on agreed compensation after a concluded contract had been established.
Issues: Whether a concluded contract under the 1997 Act precludes additional claims for interest or solatium subsequent to the agreed compensation.
Ratio Decidendi: The Court ruled that the private respondents were estopped from seeking additional relief once they had accepted the agreed compensation, and that a voluntary contract forecloses claims for interest under statutory provisions.
Result: Appeals allowed.
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Table of Contents
2. Whether a concluded voluntary agreement for compensation precludes subsequent claims for statutory interest under Section 12 of the 1997 Act — Applicability of the doctrine of estoppel. (Para 18 , 20 )
3. Voluntary agreements under Section 7(2) and 7(4) are concluded contracts that supersede other statutory award provisions, including interest under Section 12, to ensure settlement finality. (Para 5 , 6 , 7 , 8 , 21 , 22 , 23 )
4. A concluded contract voluntarily entered into under Section 7 of the 1997 Act excludes the parties from seeking further relief under other statutory provisions of the Act. (Para 7 , 8 , 21 , 22 )
5. Appeals allowed — High Court order directing payment of statutory interest set aside. (Para 25 )
6. What is the legal effect of a voluntary agreement entered into under Section 7 of the 1997 Act?
A voluntary agreement under Section 7(2) or 7(4) is a concluded contract. Once entered into, the terms of the agreement alone govern the parties, terminating the connection to other statutory provisions regarding the passing of the award. (Para 7 , 21 )
7. Does Section 12 of the 1997 Act apply to cases where compensation is settled by agreement?
No. Section 12, which provides for interest from the time of taking possession, does not apply where a voluntary agreement has been entered into, as such a contract excludes the parties from the purview of the Act's other provisions. (Para 8 , 22 )
8. How does the doctrine of approbate and reprobate apply to land acquisition settlements?
A party who accepts compensation under a voluntary agreement without protest cannot later seek additional statutory relief. This constitutes approbating and reprobating, which is prohibited as it violates the principle of fair play and estoppel. (Para 21 , 23 )
JUDGMENT :
M.M. Sundresh, J.
1. Leave granted.
2. We have heard Dr. Abhishek Manu Singhvi, the learned Senior Counsel appearing for the appellants and Ms. Aishwarya Bhati, the learned Additional Solicitor General (ASG), Mr. S Nagamuthu, the learned Senior Counsel and other learned counsel appearing for the respondents. We have perused the written arguments and the documents filed by the parties.
3. The issue for consideration in these appeals is: Whether a party to a concluded contract, voluntarily and statutorily entered into, can seek further relief by taking refuge under the statutory provisions?
4. Sections 7 and 12 of The TAMIL NADU ACQUISITION OF LAND FOR INDUSTRIAL PURPOSES ACT , 1997 (hereinafter referred to as the “1997 Act”), read as under:
Section 7 of the 1997 Act
“7. Determination of amount
(1) Where any land is acquired by the Government under this Act, the Government shall pay an amount for such acquisition which shall be determined in accordance with the provisions of this section.
(2) Where the amount has been determined by agreement between the Government and the person to whom the amount has to be paid, it shall be paid in accordance with such agreement.
(3) Where no such agreement can be reached, the Government shall refer the case to the Collector for determination of the amount to be paid for such acquisition as also the person or persons to whom such amount shall be paid:
Provided that no amount exceeding such amount as the Government may, by general order, specify to be paid for such acquisition shall be determined by the Collector without the previous approval of the Government officer as the Government may appoint in this behalf.
(4) Notwithstanding anything contained in sub-section (3), after the case is referred to the Collector under that sub-section, but before he has finally determined the amount, if the amount is determined by agreement between the Government and the person to whom the amount has to be paid, such amount shall be paid by the Collector in accordance with such agreement.
(5) Before finally determining the amount, the Collector shall give an opportunity to every person to whom the amount has to be paid to state his case as to the amount.
(6) In determining the amount, the Collector shall be guided by the provisions contained in sections 23 and 24 and other relevant provisions of the LAND ACQUISITION ACT , 1894, (Central Act I of 1894) subject to modifications that-
(a) in the said section 23, the references to the date of publication of the notification under section 4, sub-section (1) and the time of publication of the declaration under section 6 of the said Act shall be construed as references to the date of publication of notice under sub-sections (2) and (1), respectively, of section 3 of this Act; and
(b) in the said section 24, the references to the date of publication of notification under section 4, sub-section (1) and the date of publication of the declaration under section 6 of the said Act shall be construed as references to the date of publication of notice under sub-sections (2) and (1), respectively, of section 3 of this Act.
(7) For the purpose of determining the amount-
(a) the Collector shall have power to require any person to deliver to him such returns and assessments as he considers necessary;
(b) the Collector shall also have power to require any person known or believed to be interested in the land to deliver to him a statement containing as far as may be practicable, the name of every other person interested in the land as co-owner, mortgagee, tenant or otherwise, and the nature of such interest, and of the rents and profits, if any, received or receivable on account thereof for three years next preceding the date of the statement.” (emphasis supplied)
Section 12 of the 1997 Act
“12. Payment of interest.
When the amount is not paid or deposited on or before taking possession of the land, the Government shall pay the amount determined with interest thereon at the rate of [nine
