Post-award land acquisition challenges were declined where Section 64 provided an efficacious statutory remedy.

The petitioners, agriculturists and recorded Bhumiswamis in possession of land at Village Jhirniya, Tehsil Ghattiya, District Ujjain, challenged acquisition of approximately 3.665 hectares for construction of a greenfield four-lane road connecting Indore–Ujjain–Jaora.

They alleged non-compliance with the statutory procedure under the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 (“2013 Act”), including the Social Impact Assessment process, publication requirements, consent requirements, and consideration of objections.

The final award had been passed before institution of the writ petitions.

The respondents stated that, out of 1,568 beneficiaries, more than 1,300 had accepted the award and compensation amounting to approximately Rs. 387.5 crores, and that interference would delay an infrastructure project connected with preparations for Simhastha Mahakumbh, 2028.

Whether the acquisition proceedings were vitiated because objections under Sections 15 and 21 of the 2013 Act were heard or processed by the Sub-Divisional Officer rather than the Collector/competent authority?

Whether alleged non-compliance with the Social Impact Assessment, publication, consent, and other procedural requirements under the 2013 Act and the Madhya Pradesh Rules, 2015 warranted quashing of the acquisition proceedings and award?

Whether the existence of the statutory remedy under Section 64 of the 2013 Act, coupled with the passing of the final award and overriding public interest, barred or discouraged interference under Article 226 of the Constitution?

The Court applied the provisions of the 2013 Act relating to Social Impact Assessment and preliminary acquisition proceedings, including Sections 4–10 and 11; the hearing and consideration of objections under Sections 15 and 21; compensation-related provisions under Sections 26 and 28; and the statutory reference remedy under Section 64.

Section 64 permits an interested person who has not accepted the award to seek reference concerning measurement, compensation, apportionment, or rehabilitation and resettlement entitlements, subject to prescribed limitation periods.

The Court relied on Dinesh v. State of M.P., 2024 SCC OnLine SC 937, Shiv Singh v. State of H.P., (2018) 16 SCC 270, and Kesar Singh v. State of M.P., 2025 SCC OnLine MP 3827, for the principle that statutory objections must be considered by the competent authority in the prescribed manner and that the hearing of objections is a significant procedural safeguard.

It also considered Hindustan Petroleum Corpn. Ltd. v. Darius Shapur, (2005) 7 SCC 627 and Raghbir Singh Sehrawat v. State of Haryana, (2012) 1 SCC 792, concerning the importance of the right to object and the possibility of challenging acquisition for violation of mandatory procedure.

The Court acknowledged that the petitioners’ objections regarding the role of the SDO and the statutory hearing requirements were legally substantial, and reproduced authorities holding that objections under Section 15 must be heard and processed by the Collector/appropriate authority.

However, on examination of the record, it concluded that the 2013 Act and the Madhya Pradesh Rules, 2015 had been broadly and substantially complied with.

The Court placed considerable weight on the fact that the petitions were filed after the final award, that most beneficiaries had accepted compensation, and that the petitioners had not pursued the Section 64 remedy.

It held that the remaining grievances, particularly those concerning the award, compensation, measurement, and related entitlements, could be addressed through the statutory mechanism under Section 64.

Balancing the alleged procedural lapses against the larger public interest in timely completion of the road corridor and preparations for Simhastha Mahakumbh, 2028, the Court held that any minor procedural deficiencies did not justify quashing the acquisition or stalling the infrastructure project.

The Court therefore declined to exercise its discretionary jurisdiction under Article 226, while expressly refraining from commenting on the petitioners’ prospects before the statutory authority.

The Court relied on substantial compliance with the 2013 Act and the Madhya Pradesh Rules, 2015, the availability of the Section 64 remedy, the delay in approaching the Court after the award, and the overriding public interest in the infrastructure project.

Any interim relief or stay was vacated, and the signed order was directed to be placed in the lead petition with copies in the connected matters.