Subsequent amendments introducing compensation multipliers lack retrospective effect on completed land acquisition transactions.

The petitioner’s father owned land measuring 0.40 acre in Village Sahaspur, District Mungeli, which was acquired by the State under the Aapasi Sahmati Se Bhumi Kray Niti, 2016 (Mutual Consent Land Purchase Policy) for the Sahaspur Diversion Scheme

An award was passed on 18-01-2018, and the petitioner’s family received compensation totaling ₹5,16,000/- based on the prevailing 2016 guidelines, which did not include a multiplier factor

Subsequently, the State issued notifications on 30-10-2019 and 25-11-2019, amending the 2016 Policy to include a "multiplier factor of 2" for the valuation of rural land

The petitioner filed this writ petition under Article 226 of the Constitution of India seeking a mandamus to apply the multiplier factor of 2 retrospectively to their 2018 compensation

1. Whether the amendments/substitutions made to the Aapasi Sahmati Se Bhumi Kray Niti, 2016 in the year 2019, specifically the introduction of a multiplier factor of 2, have retrospective effect on transactions completed in 2018

The Court primarily applied the Aapasi Sahmati Se Bhumi Kray Niti, 2016 (specifically Clause 2(4) as it stood in 2018) and its subsequent 2019 amendments

It relied on the doctrine of prospective overruling as detailed in State of Manipur v. Surajkumar Okram (2022 SCC OnLine SC 130), which establishes that past transactions under valid statutes are saved and that laws are generally prospective unless a retrospective intent is expressed

The Court further distinguished the petitioner's reliance on Ramesh Chandra Sharma v. State of UP [(2024) 5 SCC 217], noting it involved specific High-Level Committee recommendations for additional compensation not present in this case

The Court reasoned that the land purchase transaction was finalized in January 2018 when the compensation was determined and accepted without protest by the petitioner’s father

At that time, the 2016 Policy only provided for compensation based on the effective rate of the Collector's guidelines without any multiplier

The Court rejected the petitioner's argument that the 2019 amendments were "explanatory" or "clarificatory" in nature; instead, it found that the 2019 notifications introduced a entirely "new method of calculation" and a new provision for a multiplier that did not exist in the original 2016 Scheme

Applying the principles from Surajkumar Okram, the Court held that since the 2019 amendments did not explicitly provide for retroactivity and the transaction had already attained finality, the new multiplier could not be applied to a 2018 award

The Court concluded that because the compensation was calculated according to the then-prevailing 2016 Scheme and accepted without protest, the transaction was complete and could not be reopened based on subsequent policy changes

The writ petition was dismissed, and all pending interlocutory applications were disposed of