SupremeToday Landscape Ad
Back
Next
Judicial Analysis Court Copy Headnote Facts Arguments Court observation
Listen Audio Icon Pause Audio Icon
judgment-img

2026 Supreme(SC) 93

SANJAY KUMAR, K. VINOD CHANDRAN
Niraj Jain – Appellant
Versus
Competent Authority-cum-Additional Collector, Jagdalpur – Respondent


Advocates appeared:
For the Petitioner(s) Mr. Shoeb Alam, Sr. Adv. Mr. Sahil Tagotra, AOR Ms. Shreya Kasera, Adv.
For the Respondent(s): Mr. Tushar Mehta, D.A.G. Ms. Ankita Sharma, AOR Mr. Arjun D Singh, Adv. Ms. Ishika Neogi, Adv. Mr. Brijender Chahar, A.S.G. Mr. Nachiketa Joshi, Sr. Adv. Mr. Praneet Pranav, Adv. Mr. Bhuvan Kapoor, Adv. Mr. Rajan Kumar Chourasia, Adv. Mr. Amrish Kumar, AOR Mr. Abhikalp Pratap Singh, AOR Ms. Aagam Kaur, Adv. Mr. Kartikey, Adv. Mr. Shubhangi Agarwal, Adv. Mr. Gayatri Agarwal, Adv.

Judgement Key Points

The legal reasoning in this case centers on the principle that the invalidation of a land acquisition award on the grounds of excessiveness and resulting unjust enrichment of certain beneficiaries does not automatically nullify the entire award or the entire acquisition process (!) (!) . The court emphasizes that challenges to awards are often specific to particular respondents or beneficiaries, and the scope of such challenges does not extend to all landowners or the entire acquisition unless explicitly stated (!) .

Furthermore, the court clarifies that the challenge was only against specific respondents who were implicated in alleged collusion and colorable exercise of powers, and the appellant, who was not proceeded against or implicated in the inquiry or criminal proceedings, could not be adversely affected by the orders setting aside the award for others (!) (!) . The fact that the award in favor of the appellant was not challenged by the Railways, and that the arbitral award was passed in favor of the appellant, indicates that the appellant’s rights remain intact and unaffected by the issues concerning other beneficiaries (!) (!) .

Additionally, the court notes that the challenge to the award was limited to the respondents who were specifically named and implicated in the inquiry, and the appellant’s award was not subject to such proceedings or allegations (!) (!) . The absence of any challenge by the Railways to the arbitral award in favor of the appellant further supports the conclusion that the appellant’s award should be restored and disbursed (!) .

Finally, the court highlights that the statutory framework governing the land acquisition process under the relevant Act does not confer authority to review or set aside awards on the basis of alleged excessiveness or unjust enrichment, especially when such awards are not challenged or impugned by the acquiring authority (!) .

In sum, the legal argument underscores that invalidating or setting aside part of an award, based on allegations of collusion or excessiveness involving specific respondents, does not automatically impact the rights of beneficiaries who are not implicated or challenged, and the entire award should be restored where the appellant’s award was not challenged or tainted by the proceedings against others.


JUDGMENT

K. VINOD CHANDRAN, J.

Leave granted.

2. Whether the setting aside of an award of compensation for land acquisition, on grounds of it being excessive and resulting in unjust enrichment of some land owners, acting in collusion with the competent authority and the revenue officials, who acted in colourable exercise of powers would ipso facto result in the entire award with respect to the acquisition being set aside is the question arising in this appeal.

3. Two sets of litigation arose with respect to the acquisition of land in the State of Chhattisgarh for a Special Rail Project, notified on 31.08.2017 from Rowghat-Jagdalpur (140 km) between Dallirajhara- Jagdalpur (235 km).

4. After the award was passed, certain persons also approached the Arbitrator constituted under the Land Acquisition (Special Railway Projects) Rules, 2016 [for short, the Rules of 2016] for the purpose of sub-section (6) of Section 20-F of the Railways Act, 1989 in which an enhancement was granted.

5. An inquiry was initiated, alleging excessive amounts having been awarded far greater to the actual land value. Based on the inquiry report of the Collector, an FIR was also registered against the Competent Autho

Click Here to Read the rest of this document
1
2
3
4
5
6
7
8
9
10
11
SupremeToday Portrait Ad
supreme today icon
logo-black

An indispensable Tool for Legal Professionals, Endorsed by Various High Court and Judicial Officers

Please visit our Training & Support
Center or Contact Us for assistance

qr

Scan Me!

India’s Legal research and Law Firm App, Download now!

For Daily Legal Updates, Join us on :

whatsapp-icon telegram-icon
whatsapp-icon Back to top