Principle of Res Judicata applies to award enhanced land acquisition compensation to similarly situated claimants.

The appellants’ lands situated in Village Devpura, Taluka Vav, District Banaskantha, were acquired for the Narmada Project main canal construction. Section 4 and Section 6 notifications were issued on 05.02.1997 and 10.07.1997, respectively

The Special Land Acquisition Officer awarded compensation of ₹18,600/hectare for irrigated and ₹12,400/hectare for non-irrigated land on 04.09.1999

Dissatisfied, the claimants sought ₹50/sq. mtr. via Reference under Section 18 of the Land Acquisition Act

The Reference Court granted additional compensation of ₹48.45/sq. mtr. (irrigated) and ₹38.75/sq. mtr. (non-irrigated)

The appellants filed these appeals seeking enhancement, citing a coordinate Bench judgment dated 15.07.2025 in similar matters

1. Whether the appellants are entitled to enhanced compensation based on the principle of Res-judicata or parity with related matters decided by a coordinate Bench involving the same acquisition project and similar geographical locations

Section 54 of the Land Acquisition Act, 1894, which provides for appeals against the Reference Court’s award

doctrine of Res-judicata and judicial consistency/parity, holding that once a coordinate Bench determines a fair market value for a group of matters arising from the same notification or project for adjacent villages, those findings apply to "left out" matters in the same group

The Court observed that these appeals were part of a larger group of matters arising from a common judgment and award dated 02.03.2015

The Court referred to the coordinate Bench's decision in FA No. 1999 of 2017, where it was determined that Village Devpura is only 3.00 km from Village Sandhar, for which higher compensation had already been upheld

Because the present appeals arose from the same group of Land Acquisition Reference (LAR) cases, the Court held that the principle of Res-judicata (or parity) was attracted.

Consequently, the finding that both irrigated and non-irrigated lands deserve uniform enhancement was adopted to ensure judicial uniformity

The respondents were directed to deposit the additional amount with the Reference Court within 12 weeks for disbursement to the claimants after due verification and deduction of any applicable Court fees