In a significant ruling on land acquisition compensation, the Supreme Court of India, comprising a Bench of Justice S.V.N. Bhatti and Justice N.V. Anjaria, exercised its extraordinary powers under Article 142 of the Constitution of India to grant enhanced compensation of Rs. 6,50,000/- per acre to land losers to bring them at par with other landowners under the same acquisition notification. However, considering an aggregate delay of 4,427 days in pursuing appeals, the Court disallowed interest on the enhanced amount for the delayed periods.
Background of the Case
The matter originated on February 11, 1999, when the respondents issued a notification under Section 4(1) of the Land Acquisition Act, 1894, proposing to acquire 7 Acres 12 Guntas in Survey No. 161/2 of Mudhol Village, Mudhol Taluk, Bagalkot District, Karnataka. The land was acquired to accommodate families displaced due to a project. On January 4, 2000, the Land Acquisition Officer passed an award.
Dissatisfied with the compensation, the appellants sought a reference under Section 18(1) of the Act before the Additional Civil Judge (Senior Division), Jamkhandi (LAC No. 1802 of 2000). On March 27, 2001, the Reference Court enhanced the compensation to Rs. 3,00,000/- per acre.
The appellants subsequently filed an appeal (MFA No. 20936 of 2008) before the High Court of Karnataka, Circuit Bench at Dharwad, which further enhanced the compensation to Rs. 5,00,000/- per acre on June 23, 2011.
The grievance of the appellants arose because, in a parallel proceeding (MFA No. 21191 of 2010) involving lands acquired under the very same Notification dated February 11, 1999, the compensation was determined at Rs. 6,50,000/- per acre via a High Court judgment dated December 12, 2012. That enhanced rate of Rs. 6,50,000/- per acre was later approved by the Supreme Court in Ravindra and another v. Special Land Acquisition Officer, UKP, Bagalkot (2017) 11 SCC 495.
Seeking similar parity, the appellants filed Review Petition No. 100113 of 2014 before the High Court of Karnataka, which was dismissed on September 7, 2015. The appellants then approached the Supreme Court seeking parity with the Ravindra decision.
Arguments of the Parties
The appellants sought parity in compensation for their lands covered under the same Notification dated February 11, 1999, relying on the rate approved in Ravindra and another v. Special Land Acquisition Officer, UKP, Bagalkot.
The respondents did not dispute the timeline or factual details. However, they strongly objected on the grounds that the appellants were not diligent in pursuing their claim for enhancement. The respondents contended that the appellants were not entitled to interest on the enhanced compensation for the period of delay. The respondents categorized the delay into two distinct phases:
- 2,383 days: From March 28, 2001 (following the Reference Court judgment) until the filing of the MFA before the High Court of Karnataka in 2008.
- 2,044 days: From June 24, 2011 (following the High Court MFA judgment) until the refiling of the Special Leave Petitions on January 27, 2017.
Court’s Analysis
After perusing the records, the Supreme Court condoned the delay in filing the Special Leave Petitions in the peculiar facts and circumstances of the case and granted leave.
The Bench observed that “the Appellants were agriculturists, and the agricultural land was acquired through the subject Notification.”
Addressing the issue of delay and equal treatment under the law, the Court noted: “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.”
To ensure justice while balancing the delay, the Court held: “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.”
Regarding the interest claim for the period of delay, the Court ruled: “The Appellants are not entitled to interest for the period from the date of the Reference Court’s Judgment, i.e., 28.03.2001, to the date of filing the subject MFA before the High Court of Karnataka in 2008, and from the date of disposal of the subject MFA by the High Court on 24.06.2011 to the refiling of the SLPs before this Court, i.e., 27.01.2017, aggregating to 4,427 days.”
Decision
The Supreme Court allowed the Civil Appeals. The appellants were declared entitled to enhanced compensation at the rate of Rs. 6,50,000/- per acre along with statutory benefits. However, they were denied interest for the delayed period aggregating to 4,427 days. All pending applications were disposed of accordingly.
Case Details:
Case Title: Lachchappa and Others v. Special Land Acquisition Officer UKP, Bagalkot and Others
Case No.: Civil Appeal Nos. of 2026 (@ Special Leave Petition (Civil) Nos. 5481-5482 of 2017)
Bench: Justice S.V.N. Bhatti, Justice N.V. Anjaria
Date: August 7, 2026
