Title disputes in National Highway acquisitions must be referred to the civil court under Section 3H(4).

The respondent claimed rights over two parcels of land comprised in three Dag numbers at Kanglatombi Village, Manipur, which were allegedly affected by a proposed National Highways project connecting Kanglatombi and Kangpokpi.

A joint inspection/survey was conducted on 20 April 2026 in the presence of the parties and NHIDCL officials. The parties accepted the survey report, which identified 674.75 square feet of land in CS Dag No. 1099 as required for the project.

The State undertook to initiate acquisition proceedings under the National Highways Act, 1956 and pay compensation in accordance with law; the connected writ proceedings were consequently disposed of on 28 April 2026.

NHIDCL thereafter filed the present review petition under Order XLVII Rule 1 and Section 114 of the Code of Civil Procedure, contending principally that a revenue survey could not determine title to the land.

Whether the review petition disclosed any ground under Order XLVII Rule 1 CPC—namely, discovery of new and important matter, an error apparent on the face of the record, or any other sufficient reason—to warrant review of the order dated 28 April 2026.

Whether the joint revenue survey and the consequential direction to initiate acquisition proceedings improperly determined title to the disputed land.

Whether any dispute regarding entitlement to or apportionment of compensation could be addressed under Section 3H(4) of the National Highways Act, 1956.

A review under Order XLVII Rule 1 read with Section 114 CPC lies only on the grounds of discovery of new and important matter or evidence despite due diligence, an error apparent on the face of the record, or another sufficient reason construed consistently with those grounds.

Applying Girnar Traders v. State of Maharashtra, (2011) 3 SCC 1, and In Re: Interplay Between Arbitration Agreements under the Arbitration and Conciliation Act, 1996 and the Indian Stamp Act, 1899, (2024) 6 SCC 1, the Court held that a self-contained code provides a complete statutory machinery for the subject matter and has minimal dependence on other enactments.

Under Section 3H(4), disputes concerning apportionment of compensation or the person entitled to receive it must be referred by the competent authority to the principal civil court of original jurisdiction.

Article 300A of the Constitution requires deprivation of property to be authorised by law; in the present context, acquisition under the National Highways Act constituted such authority.

The Court held that NHIDCL’s submission—that a revenue survey cannot confer or determine title—was correct only as an abstract proposition but did not establish a reviewable error.

The joint survey report, signed or accepted by the concerned parties and NHIDCL officials, did not purport to adjudicate title; it merely identified the extent of land required for the project and enabled lawful acquisition proceedings to commence.

The Court further observed that any dispute over the person entitled to compensation or the apportionment of compensation could be resolved through the mechanism in Section 3H(4) of the National Highways Act.

NHIDCL failed to produce material showing that the land had already been validly acquired or that compensation had been paid, and therefore the earlier order merely directed initiation of the statutory acquisition process rather than conclusively determining ownership.

None of the review grounds demonstrated newly discovered evidence, an error apparent on the face of the record, or any other sufficient reason.

Review Petition No. 8 of 2026 was accordingly dismissed as meritless.

In view of the regret expressed by the concerned NHIDCL officer regarding the conduct of the proceedings, the Court imposed no costs.