Disposal of land acquisition reference without hearing parties or adjudicating on merits violates natural justice.

The petitioner’s land (Survey Nos. 38 and 40) in Datia was acquired under an award dated 06.01.2016.

Alleging lack of notice, the petitioner filed a reference under Section 64 of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013, on 13.02.2017.

Delay was condoned, and evidence was concluded by 22.09.2023.

The matter was transferred to the Third District Judge, Datia, as Case No. Ex. L.A./01/2023.

Between 07.01.2026 and 28.01.2026, the proceedings were stayed pending a roster clarification from the Principal District Judge.

On 29.01.2026, the Principal District Judge directed the lower court to decide the case.

On 30.01.2026, the trial court dismissed the reference without hearing merits, leading to this petition under Article 227 of the Constitution.

1. Whether the trial court erred in dismissing the reference petition without adjudicating the framed issues on merits after the conclusion of evidence.

2. Whether the dismissal of the case without affording the petitioner an opportunity for final arguments constitutes a violation of the principles of natural justice.

Article 227 of the Constitution regarding the High Court's power of superintendence over subordinate courts.

Section 64 of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013, which governs the referral of land acquisition disputes to the Authority/Court.

Fundamental rule of natural justice (Audi Alteram Partem), which mandates that parties must be afforded a fair opportunity of hearing before a case is decided.

The High Court observed that the trial court’s record demonstrated a procedural lapse. While the case was pending for administrative clarification regarding jurisdiction and roster, it was never specifically fixed for final arguments.

The High Court noted that on 28.01.2026, the case was merely listed for "further consideration" following the Principal District Judge's instructions.

Immediately upon receiving the direction to proceed, the trial court dismissed the matter on 30.01.2026 without granting the petitioner the opportunity to address the court on the merits or the evidence already recorded.

The High Court reasoned that since evidence had already concluded, dismissing the case solely based on its "old pendency" or administrative reasons, without deciding the framed issues, was legally unsustainable and a violation of natural justice.

The Court set aside the impugned order dated 30.01.2026 and remanded the matter to the Third District Judge, Datia.

The trial court was directed to decide the case afresh on its merits after providing a due opportunity of hearing to both parties.

The parties were ordered to appear before the lower court on 24.06.2026.