The Supreme Court has held that a High Court cannot reassess or substitute a plausible determination of guideline value while exercising powers under Article 227 of the Constitution.
The bench of Justice Aravind Kumar and Justice N.V. Anjaria while setting aside the Karnataka High Court’s decision, the Court restored the Executing Court’s valuation of ₹1,000 per square foot for land acquired under a compromise decree.
The dispute arose from a 2007 settlement under which landowners were to be compensated based on the guideline value prevailing at the time if alternative land was not conveyed. Upon failure to fulfil this obligation, execution proceedings were initiated, and the Executing Court fixed the compensation at ₹1,000 per square foot based on the Karnataka Government’s guideline value notification dated April 17, 2007.
However, the High Court reduced the valuation to ₹500 per square foot by applying a different interpretation of the notification, including a 50% reduction applicable to industrial lands. This approach was challenged before the Supreme Court.
The Supreme Court ruled that such interference was impermissible under Article 227. It reiterated that supervisory jurisdiction is limited and does not allow the High Court to act as an appellate authority or substitute its own interpretation merely because another view is possible.
On merits, the Court upheld the Executing Court’s reasoning that the land, being within municipal limits, converted for industrial use, and abutting a State Highway, attracted a base value of ₹800 per square foot with a 25% increase—resulting in ₹1,000 per square foot. It rejected the application of the 50% reduction rule, holding that such a provision applies only where no specific rate is prescribed.
The Court also emphasized that valuation must strictly follow the statutory guideline notification and cannot be altered based on equitable considerations or alternative interpretations once a plausible view has been taken by the Executing Court.
On the issue of interest, the Court noted that a separate High Court order had granted 6% interest per annum from the date of the decree, and the same would continue to apply unless modified in appropriate proceedings.
Case Details
Case Title: Nandi Infrastructure Corridor Enterprises Ltd. Versus B. Gurappa Naidu & Ors.
Citation: JURISHOUR-1042-SC-2026
Case No.: Civil Appeal No.1388 Of 2013
Date: 30/04/2026
