Compensation for acquired land must reflect prevailing market value under the 2013 Act.

The respondent’s father purchased land in Survey Nos. 14 and 16 of Bommuru Agrahara Village; the land was later converted to non-agricultural use.

In connection with widening and formation of the Bengaluru–Mysuru Highway, land was acquired under the Land Acquisition Act, 1894. Although an award was made and compensation was deposited in the Assistant Commissioner’s bank account, it was neither paid to the respondent nor deposited in court.

The respondent sought acquisition and compensation for 27 guntas in Survey No. 16 under the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 (“2013 Act”).

The writ court rejected her claim that the acquisition had lapsed under Section 24(2), but directed determination and payment of compensation under Sections 26–30 of the 2013 Act. The Corporation appealed.

1. Whether the acquisition had lapsed under Section 24(2) of the 2013 Act

2. Whether depositing compensation with the Assistant Commissioner/Special Land Acquisition Officer, without payment to the landowner or deposit in court, amounted to payment

3. Whether the writ court was correct to direct compensation to be determined and paid under Sections 26–30 of the 2013 Act for the land utilized for the highway project

Section 24(2) of the 2013 Act governs when pre-existing acquisition proceedings may be deemed to have lapsed; the writ court rejected lapse on the facts of this case.

Section 31 of the Land Acquisition Act, 1894 addresses payment or deposit of compensation.

Article 300A of the Constitution protects against deprivation of property except by authority of law, and the Court held that acquisition without payment of compensation is invalid and violates Articles 14 and 300A.

Sections 26–30 of the 2013 Act provide the basis for determining compensation, including statutory components; the Court relied on Bernard Francies Joseph Vaz v. Government of Karnataka, 2025 SCC OnLine SC 20.

The Court found that compensation for the respondent’s land had neither been paid nor deposited in court, notwithstanding its deposit in the Assistant Commissioner’s bank account.

In light of the constitutional requirement that compensation accompany the State’s exercise of eminent domain, the Court upheld the direction to determine and pay compensation by applying Sections 26–30 of the 2013 Act and the cited Supreme Court decision.

It found no error in the writ court’s order.

The appeal was dismissed and the writ court’s order affirmed.

The Corporation was required to determine and pay compensation for the land utilized for the highway project in accordance with Sections 26–30 of the 2013 Act, including the applicable statutory components.