Singapogu Babu Rao & Ors. v. Special Deputy Collector (Land Acquisition) & Ors. | 2026 INSC 888 | 19 August 2026
What the case was about
When the government acquires land and several people claim the same compensation, the law prescribes a clear route: if the claimants cannot agree on how to share the money, a civil court must adjudicate. This appeal asked whether a High Court could bypass that route by sending the dispute to a Lok Adalat, and whether awards passed by the Lok Adalat could bind rival claimants who were never made parties to the settlement. The Supreme Court held that they could not.
The key facts
In 2013, the State acquired 489.04 acres in Kommepalli village for Singareni Collieries Company Ltd. under the Land Acquisition Act, 1894. The Land Acquisition Officer passed Award No. 04/2013-2014 on 30 December 2013 and, because rival claimants asserted competing rights to the compensation, referred the dispute over title and apportionment to the Principal District Judge, Khammam, under Sections 30 and 31 of the Act.
While a writ petition was pending before the High Court, the matter was referred to the Lok Adalat. The Lok Adalat passed sixteen awards on 29 March 2016. The appellants—rival claimants asserting their own title—were neither joined in those proceedings nor were they signatories to the awards. The Principal District Judge later acknowledged that the awards did not record any terms of compromise or settlement among the disputed claimants, and were passed “as if the dispute was between the Land Acquisition Officer and individual interest holder”, rather than between the rival claimants themselves (para 37).
When the appellants challenged the awards in W.P. No. 21315 of 2017, the High Court dismissed their petition. It treated the Lok Adalat proceedings as akin to a class action under Order I Rule 8 of the Civil Procedure Code, 1908, and upheld the awards. That judgment, dated 17 August 2022, was carried in appeal to the Supreme Court.
The questions before the Court
The Supreme Court framed two principal issues:
- Whether the High Court was correct in upholding the reference of the apportionment dispute to the Lok Adalat and the awards that followed.
- Whether Order I Rule 8 of the CPC, or principles thereof, could apply to proceedings before the Lok Adalat.
What the Court decided and why
The Court allowed the appeal, set aside the High Court’s judgment, and remitted the matter to the Principal District Judge, Khammam, for a fresh hearing within six months, with all parties put to proper notice (para 53).
No substitute for court adjudication. The Court held that the 1894 Act creates a strict binary for resolving compensation disputes: either all interested persons agree on apportionment under Section 29, or the Collector refers the dispute to the reference court under Section 30. The Collector has no power to finally adjudicate conflicting title claims; that duty lies with the civil court (para 32). Because the appellants and other disputing claimants had not agreed, the reference court was the only lawful forum. The Lok Adalat awards could not stand in its place.
Absence of genuine settlement. For a Lok Adalat award to be valid, it must reflect a settlement reached between the parties. Here, not all disputing title holders were parties to the proceedings, nor did they sign the awards. Regulation 17(2) of the NALSA Lok Adalat Regulations, 2009, mandates that an award must bear the signatures of the parties between whom the settlement is reached. The record showed no evidence that both sides in the compensation dispute had agreed (para 52). Consequently, the awards were non-binding on the non-signatory claimants.
Enjoyment survey is not title. The awards had relied on an “enjoyment survey” to decide who should receive the money. The Court emphasized that such a survey captures only physical occupation and “does not purport to examine the legal title, right, or interest by virtue of which such occupation is held” (para 41). When public funds are disbursed as compensation, entitlement must be determined according to law, not by who happens to be on the land at the time of the survey.
Order I Rule 8 inapplicable. The High Court had characterised the proceedings as a class action. The Supreme Court rejected this. Order I Rule 8 presupposes a “community of interest” among the persons represented. It is “wholly inappropriate to a proceeding where the subject matter of the dispute is the bone of contention between the claimants themselves and they are not the ‘two parties’ arriving at a settlement” (para 49). Rival claimants fighting each other over title and compensation do not share a common grievance capable of representation; to treat them as a single class was to erase the very dispute that Section 30 was meant to resolve.
Why it matters
The judgment reinforces that alternative dispute resolution cannot override statutory safeguards in land acquisition cases. By insisting that apportionment disputes involving conflicting title claims must be adjudicated by the reference court unless every claimant freely consents, the Court has protected landowners from being shut out of compensation by settlements they never joined. It has also closed the door on using enjoyment surveys—which merely record physical possession—as a substitute for a judicial determination of legal title. Finally, by clarifying that Order I Rule 8 has no place in adversarial claimant-versus-claimant battles, the ruling prevents future attempts to bind absent parties through mischaracterised “class” settlements. For rural landowners across the country, the decision reaffirms that their right to a court determination of title cannot be short-circuited by a Lok Adalat award they never signed.