Supreme Court Condoned Delay in Land Acquisition Compensation Appeals: Key Ruling

The Supreme Court of India recently delivered an important judgment condoning substantial delays in appeals filed by landowners seeking enhanced compensation for land acquired by the State of Haryana. The judgment, delivered by Justices Sanjay Karol and Manmohan, sets aside the Punjab & Haryana High Court’s refusal to condone delays of up to 4908 days in appeals against compensation awards.

The case relates to land acquisition proceedings initiated in 1996 for developing Sector-2 of Bahadurgarh. While the Land Acquisition Collector initially awarded compensation ranging from ₹2-4.75 lakh per acre, the Reference Court in 2005 enhanced this to ₹2.5-5.25 lakh per acre. However, several landowners failed to file appeals within the limitation period, citing various reasons including that they had entrusted documents to others who didn’t file the appeals.

The Supreme Court relied heavily on its landmark decision in Collector, Land Acquisition v. Mst. Katiji, observing: “It is common knowledge that this Court has been making a justifiably liberal approach in matters instituted in this Court… Refusing to condone delay can result in a meritorious matter being thrown out at the very threshold and cause of justice being defeated.”

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The bench noted several precedents where substantial delays were condoned in land acquisition cases, including Dhiraj Singh v. State of Haryana (where differential compensation to landowners was a factor) and Huchanagouda v. Land Acquisition Officer (where the Court considered the landowners’ poverty and illiteracy). The judgment emphasizes that while condoning delay, courts can balance equities by denying interest for the delayed period.

Quoting from Delhi Air Tech Services v. State of U.P., the Court reiterated: “While the State has the power of eminent domain, the owner of a land can only be divested thereof in accordance with the procedure established by law after appropriately compensating them.” This constitutional principle under Articles 300A and 31A formed the bedrock of the Court’s decision.

The Supreme Court allowed the appeals, condoned the delays, and remanded the matters to the High Court for fresh consideration on merits. However, it clarified that the appellants wouldn’t be entitled to interest for the condoned delay period. The Court also requested the High Court to expedite disposal given the 2005 vintage of the original award.

Petitioner Name: Suresh Kumar, Laxmi Narain & Anr..
Respondent Name: State of Haryana & Ors..
Judgment By: Justice SANJAY KAROL, Justice MANMOHAN.
Place Of Incident: Bahadurgarh, Haryana.
Judgment Date: 23-04-2025.
Result: allowed.

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