RAMPHAL & ORS. V. HARYANA STATE INDUSTRIAL AND INFRASTRUCTURE DEVELOPMENT CORPORATION LIMITED & ORS SLP (CRL.) NO. 11600-11601 OF 2025:

DATE: 13/01/2026

COURT: Supreme Court of India

BENCH: Justice Aravind Kumar and Justice Prasanna B Varale

FACTS:

The appellants, who were co-sharers and land losers, challenged the order of the High Court of Punjab and Haryana which held that co-sharers who neither filed objections to the award under Section 11 of the Land Acquisition Act, 1894 nor sought redetermination of compensation under Section 28A within the prescribed limitation were not entitled to seek relief through execution proceedings. Land belonging to the appellants and their co-sharers had been acquired pursuant to a notification issued in 2002, and an award was passed in 2003. One of the co-sharers sought reference under Section 18 of the Act and obtained enhanced compensation, which was upheld in appeal by the High Court in 2011.

The remaining co-sharers, including the appellants, did not pursue their remedies under Sections 18 or 28A of the Act. Instead, they later filed execution petitions seeking payment of compensation on the ground that the enhanced award in favour of one co-sharer should enure to their benefit. While the executing court partly allowed the execution petitions, the High Court set aside that order, holding that such execution petitions were not maintainable and that even Lok Adalat awards passed in favour of non-applicant co-sharers were without jurisdiction. Aggrieved by the denial of compensation, the land losers approached the Supreme Court.

ISSUES:

The core issues before the Court were whether co-sharers who failed to seek reference under Section 18 or redetermination under Section 28A of the Land Acquisition Act could nonetheless claim compensation on the basis of an award passed in favour of another co-sharer, and whether such co-sharers were entitled to interest despite their prolonged inaction in pursuing statutory remedies.

JUDGEMENT WITH REASONING:

The Supreme Court disposed of the appeals by holding that the appellants could not be denied their legitimate compensation merely on technical grounds, despite their failure to invoke Sections 18 or 28A of the Act. However, considering their prolonged inaction and delay, the Court limited their entitlement to interest to a period of five years preceding the date of the judgment, while denying interest for any other period.

The Court emphasized that acquisition of the appellants’ land had culminated in an award enhancing compensation in favour of one of the co-sharers, and such determination of compensation could not be ignored merely because other co-sharers had failed to pursue their remedies within time. It observed that the appellants were undisputedly land losers and blood relatives of the co-sharers who had already received enhanced compensation. Denying compensation altogether would result in inequitable and unjust enrichment of the acquiring body, particularly when the land had already been utilized for public purposes. The Court thus held that legitimate compensation for land compulsorily acquired cannot be defeated on hyper-technical or procedural grounds.

At the same time, the Court balanced equities by taking note of the appellants’ prolonged inaction. The preliminary notification was issued in 2002, the award was passed in 2003, and enhancement proceedings concluded by 2011, yet the appellants only approached the court by filing execution petitions in 2015. This lack of diligence disentitled them from claiming interest for the entire period. Recognizing that interest is compensatory in nature and premised on timely assertion of rights, the Court restricted interest to a period of five years prior to the date of judgment. This approach ensured fairness by granting substantive compensation while preventing undue benefit arising from the appellants’ own delay.

ANALYSIS:

This judgment reflects the Supreme Court’s consistent approach of prioritizing substantive justice over rigid procedural compliance in land acquisition matters. While acknowledging that the appellants failed to avail statutory remedies under Sections 18 and 28A of the Land Acquisition Act, the Court refused to allow such procedural lapses to defeat their fundamental right to receive compensation for compulsorily acquired land. The decision underscores that once compensation has been judicially determined for the acquired land, similarly situated co-sharers cannot be denied the benefit of that determination solely because they were not parties to the reference proceedings. In doing so, the Court curtailed the possibility of unjust enrichment by the State and reinforced the principle that acquisition proceedings must culminate in fair and equitable compensation to all land losers.

At the same time, the judgment carefully balances equity with accountability by denying interest for the prolonged period of the appellants’ inaction. The Court treated interest not as an automatic statutory windfall but as a compensatory relief contingent upon diligent assertion of rights. By limiting interest to five years preceding the judgment, the Court sent a clear signal that while substantive rights will be protected, litigants cannot benefit from their own delay or indifference. This calibrated approach harmonizes fairness to land losers with fiscal discipline for the State and contributes to a nuanced jurisprudence that discourages procedural abuse while preventing technicalities from undermining justice.