Land acquisition appeals involving compensation below ₹5 lakh may be dismissed for smallness without adjudicating merits.

The appellant-State challenged an award of compensation passed by the Reference Court under the land-acquisition proceedings.

The compensation amount involved in the appeal was below ₹5,00,000.

The original claimant contended that, under the State Government’s Resolution dated 25 October 2016, appeals involving compensation of less than ₹5,00,000 were to be treated as petty claims and withdrawn before the Lok Adalat; despite several Lok Adalats being held after institution of the appeal, the State had not withdrawn it.

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

Whether the High Court should entertain an appeal concerning compensation of less than ₹5,00,000 in view of the State Government’s litigation policy contained in the Resolution dated 25 October 2016?

Whether the appeal should be dismissed on account of the smallness of the amount, without adjudicating the substantive legal or compensation issues raised therein?

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were classified as petty claims and land-acquisition matters involving an amount below that threshold were to be withdrawn in the Lok Adalat.

The Court treated this resolution as a binding state litigation policy governing the conduct of the State’s appeals.

Applying that policy, the Court held that an appeal involving such a small amount need not remain pending until a future Lok Adalat and could be disposed of during regular hearing.

Since the compensation involved was below ₹5,00,000 and the State’s own litigation policy required such matters to be withdrawn in the Lok Adalat, the Court found no justification for keeping the appeal pending merely because it had not been withdrawn administratively.

Having regard to the smallness of the amount and the applicable policy, the Court declined to entertain the appeal and dismissed it on that limited ground.

The Court expressly clarified that the dismissal did not constitute an adjudication of any legal issue or of the appropriate compensation and would not operate as a precedent in other matters arising from the same notification.

The connected Civil Application was consequently disposed of as having become unnecessary.

The dismissal was declared not to decide any substantive legal or compensation issue and not to constitute a precedent.

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

The Reference Court was directed to disburse the deposited compensation, after deducting court fees and completing due verification, identification, and verification of the claimants’ entitlement, together with applicable interest.