Acceptance of a special rehabilitation package under final-settlement undertakings precluded undisclosed claims for additional benefits.

The petitioners, residents of villages Pipliya Bhoju and Roshani affected by the Aullia Medium Irrigation Project, sought rehabilitation and resettlement benefits under the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 (“2013 Act”).

They contended that the award dated 14 November 2018 did not include a separate Rehabilitation and Resettlement Award under Section 31.

The State relied on a special package under a circular dated 27 July 2018 and undertakings by the petitioners accepting the package and its benefits. Those undertakings were filed with the State’s interlocutory application in 2025; the petitions, filed in 2021, had not disclosed them.

The petitioners’ counsel stated that the petitioners were pressing the claims for a Section 31 award and acquisition of remaining lands in specified circumstances.

1. Whether the petitioners could obtain a direction for a separate Rehabilitation and Resettlement Award under Section 31 after accepting benefits under the special package and furnishing undertakings.

2. Whether the petitions could be entertained when the petitioners had not disclosed their acceptance of the package and the undertakings in their pleadings.

Section 31 of the 2013 Act was invoked by the petitioners as requiring a Rehabilitation and Resettlement Award.

Sections 23 and 38 were also mentioned in the petitioners’ challenge to the acquisition and possession process.

The petitioners relied on Ravir Singh & Ors. v. National Highway Authority of India & Competent Authority for Land Acquisition & Ors., but the Court did not apply or analyse that decision.

The Court found that the undertakings recorded acceptance of the special package and stated that the amount received would be treated as full and final settlement, while also providing for any further benefit that the Government might later grant.

The acquisition award referred to the package and provided that any shortfall between the compensation and package amount would be paid as a special grant upon the required consent.

In the Court’s view, the petitioners had accepted benefits under the package but had omitted that material fact from petitions filed in 2021; their subsequent claim for additional relief was therefore impermissible.

The Court did not separately determine the general scope of Section 31.

The Court dismissed both writ petitions, relying on their acceptance of the special package and their undisclosed undertakings.