Writ jurisdiction is precluded where Section 64 of the LARR Act provides an efficacious alternative statutory remedy.

The eight petitioners, residents of Villages Bhairotaal and Kuchena in District Korba, had their lands acquired for the construction of the Katghora-Hardibazar-Baloda-Akaltara Road under the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013

The petitioners challenged the compensation awards dated 30/08/2024 and 30/09/2004, asserting that the compensation was neither appropriate nor adequate and failed to comply with the statutory formulas prescribed under Sections 26 to 30 of the 2013 Act

They filed a writ petition under Article 226 of the Constitution of India seeking a mandamus for reassessment and payment of fair compensation, including statutory benefits like solatium and interest

Whether a writ petition under Article 226 is maintainable when an efficacious alternative remedy is available under the 2013 Act

Whether the petitioners are entitled to a fresh determination of compensation through the High Court’s extraordinary jurisdiction

The court primarily applied Section 64 of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013, which mandates that any interested person who has not accepted an award may, by written application to the Collector, require the matter to be referred to the "Authority" for determination regarding land measurement, compensation amount, or apportionment

The court also applied the judicial principle that extraordinary jurisdiction under Article 226 of the Constitution of India should not be exercised when an efficacious alternative statutory remedy exists

The court examined the petitioners' grievances, which pertained specifically to the assessment of the quantum of compensation and the alleged failure to apply statutory benefits under the 2013 Act

The respondents argued that the petition was not maintainable because Section 64 of the 2013 Act provides a specific legal mechanism for such disputes

The court agreed, noting that Section 64 is the proper statutory avenue for objections regarding the "amount of the compensation"

Consequently, the court reasoned that because a specialized statutory remedy is available, it would not be appropriate to entertain the matter under its extraordinary writ jurisdiction

To ensure justice, the court balanced this procedural dismissal by granting the petitioners liberty to approach the correct forum

The Court granted the petitioners liberty to file an application under Section 64 of the 2013 Act before the concerned Collector

Furthermore, the Court directed that if such an application is filed, the Collector shall not insist upon the period of limitation

No orders were made as to costs