Lok Adalat Cannot Decide Rival Land Titles Through an “Enjoyment Survey” or Bind Non-Signatory Claimants: Supreme Court Sets Aside Compensation Awards

Case Name: Singapogu Babu Rao and Others v. Special Deputy Collector (Land Acquisition) and Others

Date of Judgment: 19 August 2026

Citation: 2026 INSC 888

Bench: Justice J.B. Pardiwala and Justice Manoj Misra

Held: The Supreme Court held that a Lok Adalat cannot adjudicate competing claims of title or determine the apportionment of land-acquisition compensation merely on the basis of an “enjoyment survey.” Physical possession does not establish legal title or entitlement to compensation. A Lok Adalat award based on a settlement is binding only upon the parties who consented to and signed it; it cannot bind rival claimants who were neither parties nor signatories. The Court further held that competing claimants asserting adverse titles cannot be treated as a single class under Order I Rule 8 CPC because they do not possess a common interest.

Summary: The dispute arose from the acquisition of 489.04 acres of land in Kommepalli, Sathupalli Mandal, for mining operations to be undertaken by Singareni Collieries Company Limited. The Land Acquisition Officer fixed compensation at ₹3,48,935 per acre and, on finding disputes concerning title and apportionment, referred the matter to the Principal District Judge, Khammam, under Sections 30 and 31 of the Land Acquisition Act, 1894.

During the pendency of writ proceedings challenging the acquisition, the acquiring company proposed an enhanced compensation of ₹10,95,000 per acre. The matter was referred to the High Court Legal Services Committee, and a coordination meeting contemplated an enjoyment survey and resolution of the disputes through a Lok Adalat. Subsequently, the Lok Adalat passed 16 awards covering approximately 363 acres.

The appellants challenged these awards on the ground that the dispute over title and entitlement had never been adjudicated. They contended that all rival claimants were not joined in the Lok Adalat proceedings and had neither consented to nor signed the awards. The Principal District Judge also informed the High Court that the directions issued during the coordination meeting had been misunderstood. The awards had been passed in favour of individual claimants without recording any compromise among the competing title holders and without obtaining the signatures of all interested parties.

The Telangana High Court nevertheless upheld the awards. It reasoned that the awards could be treated as a settlement in a class-action proceeding by applying the principles of Order I Rule 8 CPC. It also relied upon the title documents and enjoyment survey produced by the claimants in whose favour compensation had been awarded.

The Supreme Court found this approach legally unsustainable. It explained that Sections 29 and 30 of the Land Acquisition Act provide two distinct methods for apportioning compensation. Where every interested person agrees, the apportionment may be recorded under Section 29. Where there is no complete agreement, the competing claims must be adjudicated by the competent civil court under Section 30.

The Court strongly disapproved of reliance upon the enjoyment survey. Such a survey merely records who was physically occupying the land at a particular time. It does not examine whether the person in possession is an owner, lawful assignee, legal heir, tenant, permissive occupant, encroacher or trespasser. It, therefore, cannot conclusively determine entitlement to compensation.

The Court also rejected the High Court’s treatment of the proceedings as a representative or class-action settlement under Order I Rule 8 CPC. A representative proceeding requires a common interest among the persons represented. Here, the claimants asserted mutually adverse titles and were contesting entitlement against one another. They did not constitute a common class and could not be represented by claimants whose interests were directly opposed to theirs.

Further, Regulation 17(2) of the National Legal Services Authority (Lok Adalat) Regulations, 2009 requires a Lok Adalat award to bear the signatures of the parties between whom the settlement is reached. Since all competing claimants had neither participated in nor signed the settlement, the awards could not bind the non-signatories.

Decision: The Supreme Court allowed the appeal, set aside the Telangana High Court’s judgment and quashed the disputed Lok Adalat awards. The matter was remitted to the Principal District Judge, Khammam, for a de novo adjudication of the reference concerning title and apportionment of compensation. The District Judge was directed to issue notice to all concerned parties and decide the reference within six months, uninfluenced by any observations previously made in the proceedings.