Andhra Pradesh HC Rejects Challenge to 2018 Land Acquisition Awards for SEZ expansion

The High Court of Andhra Pradesh clarified that landowners dissatisfied with compensation must approach the designated authority rather than invoke writ jurisdiction years after the award. A single-judge bench of Justice B Krishna Mohan heard a batch of writ petitions challenging land acquisition awards passed in 2017 and 2018 for the expansion of an Integrated Special Economic Zone in Anakapalli District. The Court emphasized that once awards are passed, the primary remedy for grievance redressal regarding the quantum of compensation lies under the reference mechanism provided by the statute.

The Multiplier and Compensation Dispute

The petitioners, primarily farmers from Gorapudi Village, challenged the awards on several grounds, including the application of an incorrect multiplier for rural areas and a failure to provide a rehabilitation package. They argued that the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 and its Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement (Compensation, Rehabilitation and Resettlement, Development Plan) Rules 2015 required a multiplier of 2.0 for rural areas, whereas the authorities applied only 1.25. They further contended that no notices were served under Section 21 and Section 22 of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013, and that they remained unaware of the awards until recently. The petitioners sought compensation at the rate of Rs. 50,00,000/- per acre, citing current market values, and protested the 'unilateral' fixing of a consent amount of Rs. 20 lakhs per acre.

Court Observations on Statutory Compliance and Delay

The State, represented by the Advocate General, countered that the petitions suffered from gross laches, as some petitioners were already part of previous litigations where the awards were mentioned. The State relied on Ramniklal N. Bhutta and another v. State of Maharashtra and others ( "(1997) 1 SCC 134": 1996 CaseBase(SC) 852) to argue that larger public interest in infrastructure must be balanced against private interests. Furthermore, the State cited May George v. Special Tahsildar and others ( "(2010) 13 SCC 98": 2010 CaseBase(SC) 1419) to assert that once land vests in the State after an award and possession, it cannot be easily divested.

The Court, in its reasoning, observed: "...the petitioners are not satisfied with the compensation fixed under the impugned award and as there was a special compensation amount was fixed as stated above for consent awards, same benefit can also be extended to the petitioners upon deliberations and negotiations by arriving a consensus on it."

Final Directions Issued by the Court

While refusing to quash the 2018 awards, the Court granted liberty to the farmers to seek enhancement of compensation through the statutory reference authority. The Court has the following directions:

"The petitioners are at liberty to avail the effective and alternative remedy u/s.64 of the Act 30 of 2013 and upon availing the same, notwithstanding the delay occurred if any, the said LARR authority shall consider the case of the petitioners on merits following the due procedure under the Act 30 of 2013. The possession of the subject lands can also be taken by the respondent authorities concerned following the due procedure under the said Act and rules made there under."

Background:

The dispute originated from the acquisition of approximately 417.50 acres in Gorapudi Village for the Atchuthapuram Cluster of the Visakhapatnam-Chennai Industrial Corridor. While the government had initiated proceedings under the 1894 Act, the Land Acquisition Act, 1894 eventually mandated that the awards be passed under the 2013 regime. Between 2017 and 2018, twelve separate awards were passed. The petitioners alleged they were never formally served with the awards and that the market value was mechanically fixed based on old data. The Court, however, noted that several petitioners were involved in a previous Writ Appeal (W.A. No. 727 of 2018) where the existence of these awards was noted in the State's counter-affidavit, thereby weakening the plea of ignorance.

Case Details:
Case No.: WRIT PETITION NOs: 16592, 19328, 19329, 19331, 19332, 19346, 19348, 19350, 19352, 19353, 19354 and 19725 of 2025
NeutralCitation: 2026:APHC:24275
Case Title: Lalam Sanjeevi (LR) and Others v. The State Of Andhra Pradesh and Others
Appearances:
For the Petitioner(s): JAVVAJI SARATH CHANDRA, Advocate
For the Respondent(s): THE ADVOCATE GENERAL, GP FOR HOME, SANTHI CHANDRA (Standing Counsel for APIIC), GP FOR LAND ACQUISITION, GP FOR REVENUE, GP FOR INDUSTRIES COMMERCE

Source: 2026 CaseBase(AP) 205