Land Acquisition Collector lacks locus standi to appeal against Reference Court orders setting aside its award.

The State of Himachal Pradesh issued a notification on 30.05.1986 under Section 4 of the Land Acquisition Act, 1894, to acquire land for an NCC Complex in Shimla

Following acquisition proceedings, the Land Acquisition Collector (LAC) awarded compensation for trees, structures, and land

Due to a title dispute and claims for higher compensation by Respondent No. 1, a reference was made to the District Judge under Sections 18 and 30 of the Act

On 27.12.2010, the Reference Court enhanced the compensation to Rs. 411 per square yard

The LAC (the original adjudicating authority) preferred the instant appeal under Section 54 of the Act to challenge the enhancement

Whether a Land Acquisition Collector, acting as a quasi-judicial authority, has the locus standi to maintain an appeal against an order of a Reference Court that modifies or sets aside the Collector's own award

Section 54 of the Land Acquisition Act, 1894, regarding the right to appeal

The principles established in Mohtesham Mohd. Ismail v. Special Director, Enforcement Directorate and another (2007) 8 SCC 254, which holds that an adjudicating authority exercising quasi-judicial powers cannot, in the absence of specific authorization, challenge an order passed by an appellate or reference authority that sets aside its own decision

The doctrine emphasizes that an adjudicating authority must act as an impartial tribunal and lacks personal litigative interest in the subject matter

The Court analyzed the legal standing of the LAC in the context of administrative and quasi-judicial functions.

The LAC acted as the initial adjudicating authority whose award was subsequently modified by the Reference Court

Applying the ratio in Mohtesham Mohd. Ismail, the Court reasoned that a quasi-judicial authority cannot be "aggrieved" by the reversal of its own order by a superior court, as it does not possess a "litigative interest" in the dispute

To allow such an appeal would permit an adjudicating authority to "become a judge in his own cause"

The Court found that while the Collector is an officer of the government, they function as an impartial tribunal during award proceedings and, absent specific statutory empowerment to appeal as a representative of the State, the Collector lacks the competency to challenge the Reference Court's findings

The Court upheld the preliminary objection raised by the respondents and dismissed the appeal solely on the ground of maintainability without delving into the merits of the compensation enhancement

All pending applications were disposed of accordingly