SC: Landowners entitled to enhanced compensation, but no interest for delay period in filing appeals

Case Name: Executive Engineer, Nimna Dudhna Project v. State of Maharashtra & Others
Date of Judgment: JANUARY 15, 2020
Citation: 2020 INSC 45; Civil Appeal Nos. 246–255 of 2020
Bench: Hon’ble Mr. Justice Ashok Bhushan and Hon’ble Mr. Justice M.R. Shah

Held: While affirming the High Court’s decision to enhance compensation for parity with similarly placed landowners, the Supreme Court modified the order to deny interest on the enhanced compensation for the five-and-a-half-year delay period in filing appeals. The Court reiterated that statutory benefits cannot extend to periods of inordinate delay attributable to the claimants.

Summary: Lands were acquired for the Nimna Dudhna Project. Original claimants secured enhancement of compensation from the Reference Court, which was further increased by the High Court in 2017, despite a delay of 5.5 years in filing first appeals. The appellant argued that though delay was condoned, interest and statutory benefits should not accrue for the delayed period. The Supreme Court agreed, citing Dhiraj Singh v. State of Haryana (2014), K. Subbarayudu v. Special Deputy Collector (2017), and other precedents. The Court held that a public body cannot be burdened with interest liability for delay not attributable to it, even if no such condition was recorded when delay was condoned.

Decision: Appeals partly allowed. High Court judgment modified to the extent of denying interest on enhanced compensation for delay period; rest of the award confirmed; no costs.