Appeals involving compensation below ₹5 lakh may be dismissed for smallness without adjudicating merits or creating precedent.

The State Government preferred a first appeal against an award of compensation passed by the learned Reference Court in land-acquisition proceedings.

The amount of compensation involved was below ₹5,00,000/-.

The original claimant contended that, under the State Government’s litigation policy and Government Resolution dated 25 October 2016, appeals involving compensation below ₹5,00,000/- were required to be withdrawn before the Lok Adalat and should not remain pending indefinitely.

The learned AGP did not dispute the existence or applicability of the said Government Resolution.

Whether the High Court should entertain a first appeal involving compensation of less than ₹5,00,000/- in view of the State Government’s litigation policy and Government Resolution dated 25 October 2016?

Whether dismissal of the appeal on account of the smallness of the amount would operate as a decision on the legal issues or the quantum of compensation involved?

Whether the claimant was entitled to disbursement of the deposited compensation amount with interest, subject to deduction of court fees and verification of entitlement?

The Court applied the State Government’s litigation policy embodied in the Revenue Department’s Government Resolution dated 25 October 2016, under which claims up to ₹5,00,000/- were treated as petty claims and land-acquisition matters involving less than ₹5,00,000/- were to be withdrawn before the Lok Adalat.

The Court further applied the principle that an appeal may be dismissed on account of the smallness of the amount involved where entertaining it would be inconsistent with the State’s own litigation policy.

Such dismissal is not a determination of the legal issues or the correctness of the compensation award and cannot be treated as a precedent in other matters arising from the same notification.

The compensation involved in the appeal was below the ₹5,00,000/- threshold prescribed by the Government Resolution.

Since the State Government had itself resolved that such land-acquisition claims should be treated as petty claims and withdrawn before the Lok Adalat, the Court held that the appeal ought not remain pending merely until a future Lok Adalat was convened.

In light of the small monetary value and the applicable State litigation policy, the Court declined to examine the appeal on merits and dismissed it on account of the smallness of the amount.

To avoid any wider legal consequence, the Court expressly clarified that the dismissal did not adjudicate any legal issue or the quantum of compensation and would not constitute a precedent in other cases arising from the same notification.

The connected civil application for withdrawal/disbursement was disposed of as having become infructuous.

The Registry was directed to return the record and proceedings to the concerned Court.

The Reference Court was directed to disburse the deposited compensation amount, after deducting court fees, to the claimant(s) with interest, subject to due verification, identification, and verification of their entitlement to receive the compensation.