Delhi High Court
Property and Real Estate LawAdministrative and Public Law

Landowners must receive access to acquisition records and a meaningful opportunity to supplement Section 3C objections.

Manish Panwar & Anr. vs Union Of India & Ors.

Delhi High CourtJUDGMENT: October 01, 20262 MIN READSOURCE JUDGMENT
Landowners must receive access to acquisition records and a meaningful opportunity to supplement Section 3C objections.. Manish Panwar & Anr. vs Union Of India & Ors.. Delhi High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioners challenged a notification dated 8 June 2026 issued under Section 3A of the National Highways Act, 1956, proposing to acquire part of land in Village Mehrauli, New Delhi, for works on NH 148AE.

Source reference: para. 2–5

They claimed the land had devolved upon them through their family and included a farmhouse with structures sanctioned by the MCD in 1987.

Source reference: para. 2–5

After a notice inviting objections under Section 3C was issued, the petitioners said they had not received relevant acquisition documents and that the map supplied did not clearly identify the extent of their land proposed for acquisition.

Source reference: para. 7–8

The respondents maintained that the map showed the acquisition extent and that the petitioners had already filed objections.

Source reference: para. 9–11
02

Issues

Whether the Court should interfere with the acquisition proceedings at this stage because the petitioners alleged that the acquisition documents and the extent of the proposed acquisition were unclear.

Source reference: para. 8–12, 16, 19

Whether the petitioners should receive a further opportunity to inspect the record and make submissions on their objections under Section 3C.

Source reference: para. 16–20
03

Law Applied

Section 3A of the National Highways Act, 1956 provides for notification of the Central Government’s intention to acquire land for a public purpose. Following that notification, the competent authority is to undertake inspection, survey, measurement, or other inquiry under Section 3B.

Source reference: para. 12

Section 3C permits an interested person to object within 21 days of publication of the Section 3A notification; the competent authority must provide an opportunity of hearing, may make further inquiry, and must decide whether to allow or disallow the objections.

Source reference: para. 13–15

The Court also referred to the order in Gautam Bali v. Union of India & Ors., W.P.(C) 10363/2026, which directed a meaningful opportunity to make submissions and file objections in a matter involving the same notification.

Source reference: para. 17–18
04

Reasoning

The Court found that the petitioners remained uncertain about which part of their land was proposed to be acquired and might need further time to inspect the record.

Source reference: para. 16

However, after considering the circumstances and examining the original file, it concluded that interference with the acquisition at that stage was unwarranted.

Source reference: para. 19

It instead addressed the procedural concern by allowing further inspection, additional written submissions, and one final hearing, leaving the competent authority to decide the objections in accordance with law.

Source reference: para. 20
05

Holding

The Court did not set aside or otherwise interfere with the Section 3A notification and disposed of the petition with directions.

The petitioners were permitted to inspect further documents before the concerned ADM on 7 October 2026, file further submissions by 30 October 2026, and attend a final hearing on 12 November 2026; the competent authority was directed to proceed in accordance with law.

Source reference: para. 19–22

The Court stated that the opportunity was granted in light of the case’s unique circumstances and was not to be treated as a precedent.

Source reference: para. 21
06

Acts & Sections Cited

1 provisions across 1 statute referred to in this judgment. Each provision opens on LawLens.

Advocates Act, 19611

Delhi High Court

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Manish Panwar & Anr.vsUnion Of India & Ors.

Delhi High Court · October 01, 2026

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