Post-award land-acquisition challenges were dismissed where Section 64 remedy existed and statutory procedure was substantially complied with.

The petitioners, agriculturists and recorded Bhumiswamis of Village Jhirniya, Tehsil Ghattiya, District Ujjain, challenged acquisition of approximately 3.665 hectares for construction of a Greenfield four-lane road connecting Indore, Ujjain and Jaora under the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 (“2013 Act”).

They alleged that their objections under Sections 15 and 21 were not properly considered, that the objections were heard by the Sub-Divisional Officer although the award was passed by the Collector, and that the Social Impact Assessment, publication, consent and compensation-assessment requirements were not complied with.

The respondents contended that the acquisition substantially complied with the 2013 Act and the Madhya Pradesh Rules, 2015; that a final award had been passed; that most affected landowners had accepted compensation; and that the petitioners had an efficacious remedy under Section 64 of the 2013 Act.

The Court considered the petitions together because they raised the same issue on identical facts.

Whether the acquisition proceedings were vitiated because objections under Sections 15 and 21 of the 2013 Act were heard by the Sub-Divisional Officer rather than the Collector or the appropriate Government.

Whether non-compliance with the alleged requirements concerning Social Impact Assessment, publication, consent, consideration of objections and compensation determination invalidated the acquisition proceedings.

Whether the High Court should exercise its jurisdiction under Article 226 after the final award had been passed, particularly when the petitioners had an alternative statutory remedy under Section 64 of the 2013 Act.

Whether the larger public interest in expediting the road project justified refusing interference with the acquisition proceedings.

The Court applied the 2013 Act, particularly Sections 4–11 concerning Social Impact Assessment and preliminary acquisition procedure, Section 15 concerning hearing and consideration of objections, Section 21 concerning notice, Sections 26 and 28 concerning compensation, and Section 64 providing a statutory reference against the award.

The Court considered the principle that statutory objections must be heard and dealt with in the manner prescribed by law, relying 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, which emphasise the mandatory nature of the Collector’s inquiry and the importance of an effective hearing.

It also noted that the right to object in land-acquisition proceedings is a valuable and quasi-fundamental procedural safeguard, as recognised in Hindustan Petroleum Corpn. Ltd. v. Darius Shapur, (2005) 7 SCC 627, and that acquisition may be challenged after an award where mandatory statutory requirements have been violated.

However, the Court relied on the doctrine of substantial compliance, the availability of an alternative statutory remedy, judicial restraint in public infrastructure matters, and the public-interest principles discussed in Saira Bee v. Urban Administration & Development Department, Anil Verma v. State of M.P., A.J. George v. State of Kerala, Bhimavarapu Giridhar Kumar Reddy v. Union of India, and J.K. Lakshmi Cement Ltd. v. M.P. Metro Rail Corporation Ltd.

The Court acknowledged that the petitioners’ challenge concerning the hearing of objections raised a substantial legal question, and reproduced authorities holding that the Collector must conduct the inquiry and submit recommendations to the appropriate Government.

Nevertheless, on examination of the record, it found that the statutory procedure under the 2013 Act and the Madhya Pradesh Rules, 2015 had been broadly and substantially followed.

The Court gave significant weight to the fact that the petitions were filed after the final award, that more than 1,300 of approximately 1,568 beneficiaries had accepted the award and compensation, and that the acquisition formed part of a time-bound public infrastructure project linked to preparations for Simhasth 2028.

It held that the petitioners’ surviving grievances, particularly those relating to measurement, compensation, apportionment or rehabilitation and resettlement entitlements, could be pursued under Section 64 of the 2013 Act.

Although the Court recognised that the petitioners’ arguments regarding procedural lapses were attractive, it concluded that the alleged lapses did not warrant quashing the acquisition in light of substantial compliance, the stage of the proceedings, the alternative remedy and the overriding public interest in completing the road project.

It held, in substance, that the acquisition proceedings had substantially complied with the 2013 Act and the Madhya Pradesh Rules, 2015, and that the petitioners could pursue any surviving award-related objections through the statutory remedy under Section 64, without the Court expressing an opinion on the merits or limitation of such proceedings.

Any interim relief or stay was vacated, and the order in W.P. No. 21594 of 2026 was directed to be placed in the connected petitions.