Purely factual disputes over land-acquisition measurements are not amenable to writ jurisdiction.

The petitioners challenged the correctness of a measurement-sheet dated 13 January 2025, which formed the basis for acquisition notifications dated 22 July 2025 and 3 August 2025 issued under the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 (“RFCTLARR Act”).

They contended that the measurement-sheet was contrary to the ground reality because it recorded details of an earlier acquisition rather than the actual position of the railway tracks laid for the Bullet Train Project.

The measurement had been undertaken pursuant to directions issued in an earlier proceeding, Special Civil Application No. 14504 of 2024, concerning the alleged use of excess land by the Railways.

The measurement-sheet recorded 391 square metres as excess area occupied by the Railways according to the existing railway lines.

1. Whether the High Court could adjudicate, in exercise of its writ jurisdiction under Article 226 of the Constitution, the petitioners’ factual challenge to the correctness of the measurement-sheet dated 13 January 2025.

2. Whether the acquisition proceedings initiated through the notifications dated 22 July 2025 and 3 August 2025 should be interfered with on the basis of the alleged discrepancy in the measurement-sheet.

The Court applied the principle that writ jurisdiction under Article 226 of the Constitution is not an appropriate forum for conducting a detailed factual inquiry, particularly where the dispute concerns the correctness of physical measurements and the factual position on the ground.

The Court also considered the acquisition proceedings initiated under the RFCTLARR Act, 2013, and directed that proceedings commenced through the acquisition notifications should proceed to their logical conclusion by the making of an award.

No specific judicial precedent was cited or relied upon in the judgment.

The petitioners’ challenge depended entirely on establishing that the measurement-sheet did not reflect the actual location of the railway tracks and instead recorded only the earlier acquisition position.

Determining whether the sheet accurately corresponded with the physical features on the land would require factual investigation and verification of measurements, which the Court held could not appropriately be undertaken in proceedings under Article 226.

The Court further noted that the measurement had been conducted pursuant to directions in the earlier writ proceeding and that 391 square metres had already been identified as excess occupation by the Railways.

Consequently, the alleged factual discrepancy did not justify interference with the acquisition process in writ jurisdiction.

The petitioners were permitted to pursue an appropriate civil remedy, and the dismissal of the writ petition was declared not to prejudice such proceedings.

The acquisition proceedings pursuant to the notifications dated 22 July 2025 and 3 August 2025 were directed to proceed to their logical conclusion through the making of an award.

The completion of those proceedings was held not to prevent the petitioners from instituting any future civil proceedings concerning their grievance.