Summary
| Category | Data |
|---|---|
| Court | Supreme Court of India |
| Case Number | C.A. No.-000566-000566 – 2026 |
| Diary Number | 8739/2025 |
| Judge Name | HON’BLE MR. JUSTICE SANJAY KUMAR |
| Bench | SANJAY KUMAR and K. Vinod Chandran, JJ. |
| Precedent Value | Binding |
| Overrules / Affirms | Affirms existing limits on scope of collateral challenges to awards |
| Type of Law | Administrative / Acquisition |
| Questions of Law | Whether setting aside an acquisition award on collusion grounds as to certain landowners ipso facto voids all awards under the same acquisition notification |
| Ratio Decidendi | The Court held that an inquiry report and subsequent orders invalidating excessive awards affect only those landowners and officials who were specifically proceeded against. Awards to other beneficiaries not impleaded cannot be nullified. Under the Railways Act, 1989 and the 2016 Rules no power of review or blanket recall of awards exists. |
| Logic / Jurisprudence / Authorities Relied Upon by the Court |
|
| Facts as Summarised by the Court | Acquisition for a Special Rail Project notified in 2017; awards passed in 2018 and enhanced by an Arbitrator in 2019. An inquiry found collusion and excessive compensation for certain landowners and officials leading to FIRs, freezing of accounts and writ petitions. High Court set aside awards across the board; appeal by an unaffected landowner succeeded. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts |
| Persuasive For | High Courts considering scope of collateral challenges to administrative awards |
| Distinguishes | Challenges confined to impleaded parties, not co-beneficiaries |
| Follows | Established rule that non-impleaded parties remain unaffected by collateral writ orders |
What’s New / What Lawyers Should Note
- Only those landowners or officials specifically named in an inquiry report and impleaded in challenge proceedings can have awards set aside.
- Awards in favour of non-impleaded beneficiaries remain valid despite a general writ order.
- The Railways Act, 1989 and the 2016 Rules do not confer any power on the Competent Authority or Arbitrator to review or recall awards once passed.
- Pendency of separate appeals by other beneficiaries does not automatically stay relief for unaffected parties.
Summary of Legal Reasoning
- The Court examined the scope of the Collector’s inquiry report which targeted only certain beneficiaries and officials for alleged collusion and unjust enrichment.
- It noted that only those against whom FIRs were lodged and whose accounts were frozen had challenged the awards in writ petitions.
- The High Court’s orders setting aside the awards were limited to impleaded parties; non-impleaded beneficiaries were neither accused nor impleaded.
- The Court held that under Section 20-F of the Railways Act, 1989 and the Land Acquisition (Special Railway Projects) Rules, 2016, there is no statutory power to review or recall an award once passed.
- Consequently, awards and enhancements granted to the appellant—who faced no inquiry, FIR or freezing order—could not be nullified by orders targeting others.
Arguments by the Parties
Petitioner
- He was never implicated in the inquiry report or criminal proceedings.
- No taint of collusion or unjust enrichment attached to his award.
- He was not impleaded in the Railways’ writ petition challenging awards.
Respondent
- Pendency of another Special Leave Petition by other beneficiaries warranted abeyance of the present appeal.
- High Court orders in the writ petition challenged awards generally, which should bind all beneficiaries.
Factual Background
Land acquisition was notified in August 2017 for a Special Rail Project in Chhattisgarh. Awards were passed on 12 February 2018 and enhanced by an Arbitrator on 28 June 2019. An inquiry report found excessive awards to certain landowners in collusion with officials, leading to FIRs, freezing orders and writ petitions. The High Court set aside all awards; the present appeal was filed by an unaffected landowner whose award and enhancement were restored by the Supreme Court.
Statutory Analysis
- Section 20-F(6) of the Railways Act, 1989 and the Land Acquisition (Special Railway Projects) Rules, 2016 permit arbitration and enhancement of compensation but do not confer any power of review or recall on the Competent Authority or Arbitrator once an award is passed.
Alert Indicators
- ✔ Precedent Followed