Appeals involving compensation below ₹5 lakh may be dismissed without adjudicating their merits.

The appellant-State authorities preferred a first appeal against the compensation awarded by the Reference Court in land-acquisition proceedings.

The amount involved was below ₹5,00,000. The respondent claimant contended that, under the State Government Resolution dated 25 October 2016, claims up to ₹5,00,000 were treated as petty claims and such appeals were required to be withdrawn in the Lok Adalat; consequently, the appeal should not remain pending indefinitely.

Since the appeal had not been withdrawn despite several Lok Adalats, the High Court considered it during regular hearing.

Whether the High Court should entertain a State appeal arising from land-acquisition proceedings where the compensation amount involved is less than ₹5,00,000, having regard to the State litigation policy 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 or compensation issues involved, or as a precedent in other matters arising from the same notification?

Whether the deposited compensation amount should be disbursed to the claimants after appropriate verification and deduction of court fee?

The Court applied the State Government’s Revenue Department Government Resolution dated 25 October 2016, which treats claims up to ₹5,00,000 as petty claims and directs that land-acquisition matters involving a stake below that threshold be withdrawn in the Lok Adalat.

The Court further applied the principle that, where the State’s own litigation policy requires withdrawal of a low-value appeal, the matter need not remain pending until a future Lok Adalat and may be disposed of during regular hearing.

Dismissal on the ground of smallness of the amount is not an adjudication of the legal issues or the merits of compensation and does not constitute a precedent for other matters.

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

As the State’s policy classified such land-acquisition claims as petty claims and contemplated their withdrawal through the Lok Adalat, the Court held that the appeal should not continue indefinitely merely because it had not been withdrawn administratively.

Accordingly, considering the smallness of the amount and the State litigation policy, the Court declined to examine the appeal on merits and dismissed it.

To avoid any adverse precedential or substantive effect, the Court expressly clarified that the dismissal did not determine any legal issue or the correctness of the compensation awarded.

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

The dismissal was expressly declared not to constitute a decision on any legal or compensation issue and not to operate as a precedent in other matters arising from the same notification.

The Registry was directed to return the record and proceedings to the concerned Court, and the Reference Court was directed to disburse the deposited compensation, after deducting court fee, together with interest, subject to due verification, identification, and verification of the claimants’ entitlement.