Material suppression of a prior Section 18 rejection bars writ relief.

The petitioners sought statutory benefits relating to compensation for acquired land, including solatium, additional compensation and interest, and re-determination of compensation at irrigated-land rates.

During the hearing, counsel admitted that the petitioners’ application under Section 18 of the Land Acquisition Act had been rejected in 2017.

The petition did not disclose either the application or its rejection.

When confronted with this omission, the petitioners sought to withdraw the petition.

1. Whether the petitioners’ non-disclosure of the rejection of their Section 18 application constituted material suppression warranting refusal of relief under Article 226.

2. Whether the petitioners could withdraw the petition simpliciter after the suppression was admitted.

A litigant invoking the High Court’s jurisdiction under Article 226 must disclose all material facts; suppression or distortion of material facts may justify dismissal without adjudication on the merits.

The Court relied on Amar Singh v. Union of India, (2011) 7 SCC 69, concerning the consequences of approaching the court without full disclosure.

Dalip Singh v. State of U.P., (2010) 2 SCC 114, which reiterates that the High Court may refuse writ relief where a petitioner suppresses relevant material or misleads the court.

The Court also referred to Prestige Lights Ltd. v. SBI, (2007) 8 SCC 449, for the principle that candour is foundational to the exercise of writ jurisdiction.

The Court noted that, following rejection of the Section 18 application, the petitioners had a remedy elsewhere.

The rejection of the Section 18 application in 2017 was material to the petitioners’ compensation claims and the procedural history, but it was omitted from the petition.

The petitioners’ admission of the rejection established the suppression; under the cited principles, the Court considered them not to have approached with clean hands and declined to entertain the petition on its merits.

Because the suppression was admitted, the Court also refused to permit withdrawal simpliciter.

It imposed costs of ₹5,000 on the petitioners’ counsel, payable to the specified account of the M.P. High Court Bar Association within seven days.