Two Haryana Landowners Get Enhanced Compensation Despite 2,702-Day Appeal Delay, But No Interest for Delay or Statutory Benefits: P&H HC

The appellants sought condonation of 2,702 days’ delay in filing appeals under Section 54 of the Land Acquisition Act, 1894, against the Additional District Judge, Rohtak’s award dated 5 December 2018.

The delay was attributed to the death of a predecessor-in-interest in one appeal and lack of knowledge in the other.

They contended that their compensation claims were covered by an earlier High Court order in RFA-2208-2019; the State conceded that the claims were so covered, but submitted that interest and statutory benefits should not be payable for the delayed period.

Under Section 54 of the Land Acquisition Act, 1894, an appeal may be pursued against an award in land-acquisition proceedings.

In considering delay in landowners’ appeals, courts should adopt a liberal, justice-oriented approach and avoid allowing technicality alone to defeat a just compensation claim, as reiterated in Suresh Kumar v. State of Haryana, 2025 SCC OnLine SC 896, and Urban Improvement Trust v. Vidhya Devi, 2024 SCC OnLine SC 3725.

However, under New Okhla Industrial Development Authority v. Rameshwar @ Ramesh Chandra Sharma, 2022 SCC OnLine SC 1599, while delayed appeals may be entertained and enhanced compensation granted, the acquiring body should not be made liable for statutory benefits and interest attributable to the period of delay.

Applying the liberal approach endorsed in the cited Supreme Court decisions, the Court accepted the appellants’ explanations and the State’s concession that their compensation claims were covered by the earlier order in RFA-2208-2019.

It therefore condoned the substantial delay and allowed the appeals on the basis of that order. Consistent with New Okhla Industrial Development Authority, however, it excluded interest and statutory benefits for the 2,702-day delayed period.

The appeals were allowed in terms of the High Court’s order dated 10 April 2026 in RFA-2208-2019, but the appellants were denied interest and statutory benefits for the delayed period.

Any pending applications were also disposed of.