Second Review Not Maintainable Merely Because Similarly Situated Landowners Subsequently Secured Higher Compensation; Finality of Earlier Review Cannot Be Reopened on Ground of Parity: Punjab & Haryana High Court

Case Name: Joginder Singh v. State of Haryana and Others

Date of Judgment: 07 August 2026

Citation: RA-RF-13-2020 in RFA-2523-2015 and connected cases.

Bench: Hon’ble Mr. Justice Jagmohan Bansal

Held: The Punjab & Haryana High Court held that a second review application cannot be entertained merely because similarly situated landowners subsequently obtained a favourable order enhancing compensation. Where the applicant’s earlier review had already been dismissed both on limitation and merits, and the SLP against that order was also dismissed by the Supreme Court, the matter had attained finality and could not be reopened on the ground of parity. Relying on Govt. of NCT of Delhi v. K.L. Rathi Steels Ltd., 2024 SCC OnLine SC 1090, the Court reiterated that a subsequent judicial decision does not furnish a ground to review an earlier concluded order within the parameters of Order XLVII CPC.

Summary: The applicants sought review of the High Court’s earlier judgment dated 03 March 2016, whereby the market value of their acquired land had been determined at ₹1,013 per sq. yard. The principal applicant had earlier approached the Supreme Court, which left open the question regarding the appropriate method of determining compensation for consideration by the High Court in review. His subsequent review application, however, was dismissed on 26 May 2017 on limitation as well as merits, and the SLP challenging that dismissal was also rejected by the Supreme Court.

The present second review was prompted by a subsequent order dated 14 November 2018, in which the High Court allowed review applications filed by other landowners whose lands had been acquired under the same notification and re-determined the market value at ₹1,051 per sq. yard. The applicants claimed parity and argued that this subsequent favourable order created a fresh cause of action.

The High Court rejected the contention. It observed that even if the applicants’ claim on merits might be covered by the subsequent decision concerning other landowners, their earlier review proceedings had already attained finality. A subsequent favourable order in another landowner’s case could not be used to reopen the concluded judgment through a second review.

Decision: The Punjab & Haryana High Court dismissed the review applications, holding that the applicants could not maintain a second review on the basis of a subsequent order granting enhanced compensation to other similarly situated landowners. Since the earlier review had been dismissed on both limitation and merits and the SLP against that dismissal had also failed, the concluded order could not be reopened merely on the ground of parity.