Facts
The petitioners challenged land acquisition for the Nathdwara–Nathdwara Town railway line.
Source reference: pp. 6–12, para. 3A notification under Section 20-A of the Railways Act, 1989, dated 29 December 2023 included their lands; after they filed objections, the Competent Authority rejected them by order dated 9 April 2024, and a declaration under Section 20-E followed.
Source reference: pp. 6–12, para. 3The petitioners alleged that the alignment was altered arbitrarily, their objections were not properly considered, and they were denied an effective hearing because notice of the hearing was published only one day beforehand.
Source reference: pp. 24–28, paras 26–27In later petitions, they also challenged the preparation of a draft compensation award before claims had been invited under Section 20-F(4).
Source reference: pp. 12–13, paras 13–14; pp. 33–38, paras 29–30Following an interim direction, the parties submitted compensation representations to the Competent Authority, which issued a report dated 3 July 2026.
Source reference: pp. 12–13, paras 13–14; pp. 33–38, paras 29–30Issues
1. Whether the Sub-Divisional Officer remained competent to act as the Competent Authority after the later Section 20-A notification.
Source reference: pp. 18–22, paras 25–25.62. Whether the petitioners’ objections were considered and whether the hearing notice afforded a meaningful opportunity to be heard.
Source reference: pp. 24–30, paras 26–27.23. Whether the altered railway alignment and selection of the petitioners’ lands were arbitrary or otherwise legally unsustainable.
Source reference: pp. 30–33, paras 28–28.34. Whether preparation of a draft award before inviting claims violated Section 20-F(4) and (5).
Source reference: pp. 33–37, paras 29–29.45. Whether the Court could examine the Competent Authority’s compensation report dated 3 July 2026 when it had not been specifically challenged.
Source reference: pp. 37–38, paras 30–30.1Law Applied
Under Sections 2(7A), 2(26) and 2(37A) of the Railways Act, 1989, the Central Government may authorise a person by Gazette notification to perform the functions of Competent Authority for a specified area and Special Railway Project; a subsequent acquisition notification does not, without more, terminate that authorisation.
Source reference: pp. 19–22, paras 25.2–25.6Section 20-D requires an opportunity for an objector to be heard, while the application of natural-justice principles depends on the circumstances and the prejudice shown; the Court relied on P.D. Agrawal v. State Bank of India, (2006) 8 SCC 776.
Source reference: pp. 28–30, paras 27–27.2Judicial review ordinarily does not substitute the Court’s view for that of technical authorities on railway alignment absent established legal infirmity, mala fides or manifest arbitrariness; the Court relied on Alok Kotahwala v. Jaipur Metro Rail Corporation Ltd., 2026 SCC OnLine SC 1324.
Source reference: pp. 31–33, para. 28.1Section 20-F(4) and (5) requires public notice inviting claims before final determination of compensation; a draft assessment is not itself a final determination.
Source reference: pp. 34–36, paras 29.1–29.2Disputes over the amount determined may be referred to arbitration under Section 20-F(6).
Source reference: pp. 34–36, paras 29.1–29.2The Court also confined its review to matters and reliefs properly put in issue.
Source reference: pp. 37–38, para. 30.1Reasoning
The Court held that the SDO’s Gazette authorisation of 10 January 2022 concerned the same Special Railway Project and had not been shown to have been withdrawn or superseded; the later Section 20-A notification therefore did not, by itself, end the officer’s authority.
Source reference: pp. 19–22, paras 25.2–25.6Read as a whole, the order rejecting the objections recorded the petitioners’ concerns and the Railway’s response, and the Court found no sufficient basis to conclude that the objections had been ignored.
Source reference: pp. 24–27, paras 26.1–26.2Although the hearing notice preceded the hearing by only one day, the petitioners did not identify material they were prevented from presenting or otherwise demonstrate specific prejudice.
Source reference: pp. 28–30, paras 27–27.2The proposed alternative lands and objections to the realignment did not establish a legal infirmity warranting the Court’s substitution of its judgment for the technical authorities’ assessment.
Source reference: pp. 30–33, paras 28–28.3As to compensation, the petitioners had not shown that the document described as a draft award was a final determination made before claims were invited; the Court therefore found no completed breach of Section 20-F(4) on the record before it.
Source reference: pp. 34–37, paras 29.1–29.4The 3 July 2026 report was not specifically challenged, so its validity was not decided.
Source reference: pp. 37–38, paras 30–30.1Holding
The Court found no sufficient ground to invalidate the acquisition proceedings: the Competent Authority’s appointment remained operative, the objections and hearing challenge did not establish a vitiating defect, the alignment challenge did not warrant judicial interference, and the evidence did not establish that a final compensation determination had preceded the statutory opportunity to submit claims.
All writ petitions were dismissed.
Source reference: p. 39, paras 31–33The petitioners’ entitlement to compensation under the applicable statutory provisions and remedies remained protected.
Source reference: p. 39, paras 31–33Acts & Sections Cited
2 provisions across 2 statutes referred to in this judgment. Each provision opens on LawLens.
Railways Act, 19891
Advocates Act, 19611
Original Court PDF
JAMNADAS SANADHYAvsUNION OF INDIA
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