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2026 Supreme(Mad) 1129

IN THE HIGH COURT OF JUDICATURE AT MADRAS 
SUSHRUT ARVIND DHARMADHIKARI, CJ., G.ARUL MURUGAN, J.
The Commissioner of Land Administration – Appellant 
Versus
Rajini Sasikanth, W/o. S.Sasikanth – Respondent
W.A.Nos.883, 786, 790, 925, 926 & 872 of 2026 C.M.P.Nos.9346, 8119, 8168, 9253, 9721 &, 9723 of 2026
Decided On : 28-04-2026 

Advocates Appeared:
For the Appellant :Mr.M.Suresh Kumar Additional Advocate General Assisted by Mr.D.Ravichander Special Government Pleader, Mr.Abishek Murthy
For the Respondent: Mr.AR.L.Sundaresan Senior Counsel for Mr.Vikram Veerasamy

Once Section 3(1) notification is issued recognizing land owners, and registered deeds and pattas remain unassailed, claimants are entitled to compensation and deposit under Section 10(3) cannot be ordered without proving title dispute.

Headnote:(A) Tamil Nadu Acquisition of Land for Industrial Purposes Act, 1997 - Sections 2(g), 2(h), 3, 4, 6, 7, 10 - Tamil Nadu Patta Pass Book Act, 1983 - Sections 3, 4, 6 - Land Acquisition - Payment of Compensation - When land is notified under Section 3(1), it vests absolutely in Government free from encumbrances and the owner/persons interested are entitled to compensation - Section 7 mandates determination of compensation through private negotiation or enquiry by competent authority and Section 10 mandates payment of determined compensation unless any of the contingencies under Section 10(3) are present

(B) Revenue records and patta - Issuance of patta creates presumption of validity and correctness - Patta is not conclusive proof of title but when registered sale deeds and pattas remain unassailed for decades and no dispute is raised by State, land owners are entitled to receive compensation - Burden of proof is on State to disprove title when it is the custodian of revenue records

Facts of the case:
Government issued notification under Section 3(1) for acquiring patta lands for industrial park and after rejecting objections, the lands vested with the State subject to payment of compensation as per Section 7. Land owners submitted registered title deeds and pattas during enquiry under Section 7(3), but the authority directed deposit of compensation in court citing Settlement Register of 1956 showing land as Government Poramboke. Writ petitions were allowed directing release of compensation which was challenged in these appeals.

Findings of Court:
Once Section 3(1) notification is issued recognizing the claimants as owners/persons interested and pattas have been issued by the Revenue authorities and remain unassailed, there is presumption of validity under the Patta Pass Book Act. Registered sale deeds spanning over four decades remain unchallenged and the State failed to discharge burden of disproving title. The decision to direct deposit in court violates right to property under Article 300A. The writ court rightly set aside the orders directing deposit and permitted withdrawal of compensation.

Issues: The main issues were whether the land owners were entitled to receive compensation without establishing title beyond the patta and registered sale deeds, whether the State could direct deposit citing old settlement records without proving dispute as to title, and whether the writ court could decide entitlement to compensation.

Ratio Decidendi: When Government acquires land by issuing notification in the name of the claimants, calls them for private negotiation and thereafter conducts enquiry, and the claimants produce registered title deeds and pattas which remain unassailed, there is no dispute as to title justifying deposit under Section 10(3). The claimants are entitled to receive the compensation and the authorities cannot unilaterally direct deposit merely based on old settlement records without proving contrary title.

Result: Writ appeals dismissed. No costs.

Table of Content
1. grouping of the appeals and identification of common issue relating to land acquisition awards. (Para 1 , 2 , 3 , 4)
2. factual narrative of acquisition proceedings, including notifications, objections, negotiations, and deposit of compensation. (Para 5)

JUDGMENT :

G.ARUL MURUGAN, J.

1.Since the issue involved in all these intra-court appeals is in respect of the awards passed by the 2nd appellant/Special District Revenue Officer in the land acquisition proceedings initiated for establishment of the SIPCOT industrial park, the appeals are heard together and disposed of by this common order.

2. W.A.No.926 of 2026 and W.A.No.925 of 2026 assail the order dated 17.10.2025 in W.P.No.21220 of 2025 and W.P.No.21217 of 2025, whereby the impugned awards of the 2nd appellant dated 11.04.2025 and 03.04.2025 in Award Nos.14 of 2025 and 12 of 2025, were set aside and the writ petitioners were allowed to file application for withdrawal of the compensation deposited.

3. W.A.Nos.883 of 2026, 790 of 2026, 786 of 2026 and 872 of 2026 arise out of the orders passed in W.P.Nos.3903 of 2026, 3934 of 2026, 3900 of 2026 and 3896 of 2026 respectively, whereby the writ petitions were also disposed of vide orders dated 19.02.2026 in favour of the writ petitioners, by following the order dated 17.10.2025 passed in W.P.No.21220 of 2025. The State has preferred the above writ appeals, challenging the separate orders passed by the writ court.

3.1.For the sake of convenience, the parties are referred as per their ranking in the lead case in W.A.No.926 of 2026 and the facts of that case are mentioned and narrated hereunder.

4. For easy reference, the details of appeals are set out as under:-

5. The common and relevant facts to be noted in these appeals are as follows:-

5.1. The Government issued G.O.(Ms.)No.180 Industries, Investment Promotion and Commerce [SIPCOT-LA] Department, dated 12.08.2022, according administrative sanction for acquisition of an extent of 908.26.70 hectares of patta land and also for alienation of an extent of 76.91.00 hectares of poramboke lands in Manellore, Soorapoondi, Sanaputhur, Madharpakkam and Vaniyamalli Villages in Gummidipoondi Taluk of Tiruvallur District, in favour of the State Industries Promotion Corporation of Tamil Nadu [SIPCOT], for establishment of an industrial park.

5.2. The project covered an extent of 11.46.00 hectares of patta lands in Madharpakkam Village of Gummidipoondi Taluk. The land acquisition proceedings were initiated and the preliminary notification for acquisition of these lands under the Tamil Nadu Acquisition of Land for Industrial Purposes Act, 1997 , [hereinafter referred to as “the Act”] was issued on 21.08.2023.

5.3. As the lands of the writ petitioners formed part of the proposed acquisition, the 2nd appellant had issued notice in Form-A dated 21.08.2023 as per Section 3 (2) of the Act, calling for their objections. The writ petitioners had filed their objections. Pursuant to the enquiry conducted, the objections and remarks of the beneficiary were forwarded to the 1st appellant. By order dated 19.07.2024, the 1st appellant rejected the objections for land acquisition, which was also communicated to the writ petitioners.

5.4. Notification under Section 3 (1) of the Act was approved by the 1st appellant and published in the Tamil Nadu Extraordinary Gazette No.238, Part-VI Section-1 dated 22.07.2024. In view of the notification published, notice under Section 7 (2) was issued on 14.08.2024 by the 2nd appellant to all the land owners/writ petitioners calling for private negotiations to determine the compensation. The 2nd appellant conducted the private negotiations on 20.09.2024, where the land owners/writ petitioners attended and they were informed that a compensation has been fixed at Rs.50 Lakhs per acre for the lands, as per G.O.(Ms.)No.46 dated 15.03.2024, which can be determined.

5.5. As the land owners/writ petitioners were not willing to enter into private negotiations and receive th

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