SC Invokes Article 142 To Grant Parity In Land Acquisition Relief

Invoking its extraordinary constitutional powers, the Supreme Court extended enhanced land acquisition compensation to landowners despite an abnormal delay of over 4,400 days, while depriving them of interest for the delayed period. The decision reinforces the mandate of equal compensation under identical acquisition notifications while balancing equity by denying interest for periods of extreme inertia.

A Division Bench comprising Justice S.V.N. Bhatti and Justice N.V. Anjaria adjudicated on the civil appeals seeking parity in compensation awarded for lands acquired under a common statutory notification.

Parity in Land Acquisition Compensation

The Supreme Court observed that even though the delay on the part of the appellants was abnormal, the fact remained that compensation for lands under the very same acquisition notification had already been finalized at a higher rate by the apex court in Ravindra and another v. Special Land Acquisition Officer, UKP, Bagalkot ( "(2017) 11 SCC 495": 2016 CaseBase(SC) 1337). Relying on its inherent jurisdiction under Article 142 of the Constitution of India, the Court extended the enhanced compensation of Rs. 6,50,000/- per acre along with statutory benefits to the appellants.

To balance the equities, the Bench explicitly denied interest for the delayed duration of 4,427 days spanning across the reference and appellate stages. The Court, in its reasoning, observed: "The delay is abnormal. The reasons recorded by the High Court for not entertaining the Review are available in the facts and circumstances of the case. But the fact of the matter is that, under the very same Notification, the compensation has been fixed at Rs. 6,50,000/- per acre, with statutory benefits. In the circumstances of this case, in exercise of our jurisdiction under Article 142 of the Constitution of India, we extend the compensation determined by this Court in Ravindra (supra) to the Appellants as well."

Background

On February 11, 1999, the state respondents issued a notification under Section 4(1) of the Land Acquisition Act, 1894 to acquire land measuring 7 Acres 12 Guntas in Mudhol Village, Bagalkot District, Karnataka, to rehabilitate displaced families. The Land Acquisition Officer issued an award on January 4, 2000. Seeking enhancement, the appellants filed a reference under Section 18(1) of the Land Acquisition Act, 1894, wherein the Reference Court increased the compensation to Rs. 3,00,000/- per acre in March 2001. On further appeal, the High Court of Karnataka enhanced it to Rs. 5,00,000/- per acre in June 2011.

In parallel proceedings arising from the exact same notification dated February 11, 1999, the compensation was ultimately fixed at Rs. 6,50,000/- per acre, which was affirmed by the Supreme Court in Ravindra and another v. Special Land Acquisition Officer, UKP, Bagalkot ( "(2017) 11 SCC 495": 2016 CaseBase(SC) 1337). The appellants sought review before the High Court for parity, which was dismissed in September 2015. Aggrieved, the appellants approached the Supreme Court.

The respondents contended that the appellants lacked diligence, suffering a cumulative delay of 4,427 days across two periods between the Reference Court judgment and the appeal before the High Court, and between the High Court appeal disposal and the refiling of SLPs in the Supreme Court. Accepting the plea of parity while disallowing interest for 4,427 days, the Supreme Court allowed the civil appeals.

Case Details:
Case No.: Civil Appeal Nos. of 2026 (@ SLP (C) Nos. 5481-5482 of 2017)
Neutral Citation: 2026 INSC 815
Case Title: Lachchappa and Others v. Special Land Acquisition Officer UKP, Bagalkot and Others

Source: 2026 CaseBase(SC) 757