The Supreme Court has held that landowners cannot reopen compensation issues already settled in earlier verdicts.

The bench of Chief Justice of India Surya Kant and Justice Nongmeikapam Kotiswar Singh has dismissed an appeal seeking further enhancement of compensation for land acquired in Village Fazalwas, Tehsil Manesar, District Gurugram, Haryana, holding that the issue had already been conclusively settled in an earlier judgment concerning the same acquisition proceedings. 

The bench affirmed the compensation awarded by the Punjab and Haryana High Court and directed the authorities to deposit any remaining amount payable to the landowner within eight weeks.

Before addressing the merits of the dispute, the Supreme Court considered an application seeking condonation of an extraordinary delay of 846 days in filing the Special Leave Petition. 

The Court noted that the matter had initially been taken up in January 2025 and that consideration of the delay issue had been deferred because a related matter involving the same land acquisition had already been reserved for judgment by the Court. 

Subsequently, after the related judgment was delivered, the present case was not immediately listed for pronouncement due to administrative reasons, resulting in a substantial delay in disposal.

Taking note of these circumstances, the Court condoned the delay, granted leave, and proceeded to decide the appeal on merits. 

The dispute arose from land acquisition proceedings initiated by the Haryana Government through a notification issued under Section 4 of the Land Acquisition Act, 1894, on April 25, 2008, followed by a declaration under Section 6 on March 9, 2009. The acquisition involved land situated in Village Fazalwas, located in the rapidly developing Manesar-Gurugram region. 

The Land Acquisition Collector passed Award No. 20 on August 24, 2009, fixing the market value of the acquired land at ₹30 lakh per acre. Dissatisfied with the valuation, the landowner sought a reference for enhancement of compensation. 

The Reference Court partly accepted the claim of the landowners and, through its award dated November 15, 2013, enhanced compensation substantially to approximately ₹62.14 lakh per acre. However, the landowner remained dissatisfied and pursued a further challenge before the Punjab and Haryana High Court. 

The High Court, through a common judgment dated May 30, 2022, adopted the belting method for determining compensation. Recognizing the superior commercial potential of lands situated close to National Highway-8, the High Court awarded compensation at the rate of ₹1.21 crore per acre for lands abutting the highway up to a depth of five acres.

For lands situated beyond that depth, however, the High Court maintained the compensation determined by the Reference Court. The High Court thus created two separate compensation categories based on proximity to the highway and resultant development potential. 

The principal issue before the Supreme Court was whether the compensation awarded by the High Court required further enhancement.

The Court observed that the controversy was no longer open for reconsideration because it had already been examined in detail in Krishan Kumar v. State of Haryana and Others, a decision delivered on May 7, 2025. That case involved acquisition of lands situated in Villages Kukrola and Fazalwas under the same acquisition proceedings. 

In Krishan Kumar, the Supreme Court had rejected the claims of landowners seeking higher compensation and had also dismissed appeals filed by the State of Haryana and the Haryana State Industrial and Infrastructure Development Corporation (HSIIDC) seeking reduction of compensation. The Court had therefore upheld the compensation framework already determined for the acquisition. 

Since the present appeal arose from the same acquisition and related to land situated in Village Fazalwas, the Bench held that the matter was squarely covered by the earlier precedent and did not warrant any fresh examination. 

The Supreme Court dismissed the appeal and affirmed the High Court’s judgment. The Court ruled that the appellant would be entitled only to the compensation already determined by the High Court together with all statutory benefits available under the Land Acquisition Act, including solatium and interest, subject to adjustment of amounts already received. 

To ensure timely implementation of the award, the Court directed the respondent authorities to deposit before the Reference Court any balance amount payable to the appellant within eight weeks. It further instructed that any amount already deposited but not yet disbursed should be released to the appellant without avoidable delay after due verification and in accordance with law. 

Case Details

Case Title: Gopala Agri Farms Pvt. Ltd. versus The State of Haryana and others 

Citation: JURISHOUR-1473-SC-2026

Case No.:  Diary No. 60376 / 2024

Date: 29/05/2026

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