Government must sanction and disburse enhanced land acquisition compensation and statutory interest within fixed timelines.

The Petitioners’ land was acquired by the State via a notification dated 15.02.1979

Following a successful reference under Section 18 of the Land Acquisition Act, 1894 by other parties in 1999, the Petitioners filed an application under Section 28-A of the Act for redetermination of compensation

The Zone Officer, L.A. & R.R. Zone, Deogarh, allowed the application on 13.04.2015, enhancing the compensation

Despite the order being passed in 2015 and records being submitted to the Department of Water Resources for sanction, the differential amount remained unpaid for over a decade

The State sought an additional three months to process the sanction during the proceedings

1. Whether the State’s delay in sanctioning and disbursing enhanced compensation awarded under Section 28-A of the Land Acquisition Act, 1894, constitutes an actionable failure of statutory duty

The Court applied the provisions of the Land Acquisition Act, 1894, specifically Section 28-A, which mandates the redetermination of compensation for land coverers of the same notification based on awards passed by the Collector or Court

It also exercised its extraordinary jurisdiction under Articles 226 and 227 of the Constitution of India to ensure the right to compensation and timely execution of statutory orders

The Court expressed strong "exception" to the State's request for further time, noting the egregious delay where land acquired in 1979 had still not been fully compensated as of 2026

It observed a significant "laxity" on the part of the Zone Officer and the Director of R&R in the Department of Water Resources, noting that even after the 2015 enhancement order, it took six years (until 2021/2023) just to submit records to the Government for sanction

The Court reasoned that since the entitlement was already determined in a quasi-judicial proceeding under Section 28-A, the administrative delay in sanctioning funds was unjustifiable and prejudiced the land losers

Furthermore, the Court ordered that the differential compensation amount, along with all statutory dues and interest, must be disbursed to the Petitioners following proper verification by the end of July 2026