An order directing statutory determination without deciding merits is not recallable; consequential findings must be separately challenged.

Private respondents had earlier filed WPC No. 1035 of 2026 alleging that their land had been used by Jindal Steel Limited for an electric line, underground pipeline and road without compensation, alternative land or rehabilitation. On 11 March 2026, the High Court directed the Collector, Raigarh to decide their application dated 16 May 2024 and to take appropriate action in accordance with law; if the land was found to have been utilised by Jindal Steel since 2005, compensation, rehabilitation and other benefits were to be provided after following due process.

Pursuant to that order, the authorities conducted an inquiry through the concerned Halka Patwari. The report stated that Khasra Nos. 69/1, 69/2, 69/3, 72/1 and 72/2 had been utilised by Jindal Steel for an electric line, underground pipeline and road. Consequently, the Sub-Divisional Officer (Revenue)-cum-Land Acquisition Officer, Raigarh issued communication dated 17 June 2026 seeking a proposal for acquisition of the land so that compensation could be determined and paid to the affected persons.

Jindal Steel filed the present miscellaneous civil case seeking recall of the order dated 11 March 2026, contending that the underground pipeline and electric line had been installed around 1997, that the claim was belated, and that the subsequent action had been taken without notice or an opportunity of hearing.

Whether the order dated 11 March 2026 in WPC No. 1035 of 2026 required recall on the ground that it was passed without notice or hearing to Jindal Steel?

Whether the subsequent inquiry report and communication dated 17 June 2026, proposing acquisition and compensation, could be challenged in the miscellaneous civil case?

Whether the High Court’s earlier order had determined the merits of Jindal Steel’s liability to pay compensation or the private respondents’ entitlement to compensation?

The Court applied the constitutional protection of property under Article 300A of the Constitution, under which no person may be deprived of property except by authority of law and in accordance with due process.

It further applied the principle that a court’s order directing a statutory authority to consider an application and act in accordance with law does not, by itself, adjudicate the substantive rights or liabilities of the parties.

The Court also recognised that any challenge to a subsequent administrative communication, inquiry report, or claim for compensation must be pursued through an appropriate legal proceeding against that decision or its underlying basis.

The Court examined the operative directions in the order dated 11 March 2026 and found that the earlier order contained no finding on the merits of the dispute. It merely directed the Collector to decide the private respondents’ application and, if the land was found to have been utilised by Jindal Steel since 2005, to provide compensation and other benefits after following due process.

The later Patwari inquiry and communication seeking an acquisition proposal were therefore steps taken by the authorities in purported compliance with that direction, rather than consequences of a final adjudication by the High Court.

Since the earlier order neither conclusively determined Jindal Steel’s liability nor finally declared the private respondents’ entitlement, the alleged absence of notice at the earlier stage did not justify recalling the order.

The Court clarified that Jindal Steel could separately challenge the inquiry report, the communication dated 17 June 2026, and the private respondents’ entitlement to compensation in accordance with law.

Accordingly, the application for recall was dismissed at the motion stage.

The Court left it open to Jindal Steel to challenge the inquiry report, the communication dated 17 June 2026, and the private respondents’ entitlement to compensation through an appropriate legal remedy.