Supreme Court of India· 19 August 2026
Does a Lok Adalat award settling compensation with certain landowners bind, or serve as an exemplar against, a claimant who did not consent to that settlement?
SINGAPOGU BABU RAO & ORS v. SPECIAL DEPUTY COLLECTOR (LAND ACQUISITION) & ORS
2026 INSC 888 · CIVIL APPEAL NO. 7838 OF 2024
Coram: J.B. Pardiwala; Manoj Misra
Answer
No. A Lok Adalat award is binding only on the parties who entered into the settlement; a claimant who did not agree to it and instead pursued his legal remedy cannot be bound by it, nor can it be relied upon as an exemplar against him.
Headnote
Land Acquisition Act, 1894 — Sections 29, 30, 31 — apportionment of compensation among rival claimants — Lok Adalat award — Code of Civil Procedure, 1908, Order I Rule 8 —
Section 29 apportionment agreement — concurrence of all persons interested —
Held: An agreement on apportionment of compensation under Section 29 of the Act, 1894 necessarily requires the concurrence of all persons interested; a partial or truncated consensus, wherein some claimants are excluded, cannot take effect as an "agreement" within the meaning of Section 29. (¶34, 45)
Lok Adalat awards characterised as class action settlement under Order I Rule 8 CPC —
Held further: Order I Rule 8 of the Code of Civil Procedure, 1908 presupposes a community of interest among the persons represented; where rival claimants are themselves in dispute over entitlement to compensation, there is no common interest capable of representation, and characterising such awards as a class-action settlement compounds rather than cures the infirmity. (¶47-49)
enjoyment survey — cannot determine title or entitlement —
Held further: An enjoyment survey captures nothing more than the fact of physical occupation and does not examine legal title, right, or interest; its findings cannot be treated as conclusive of entitlement to compensation. (¶40-41)
impugned judgment set aside — remitted for de novo hearing —
Held further: The impugned judgment was set aside and the matter remitted to the Principal District Judge, Khammam, for a de novo hearing of the apportionment reference within six months, uninfluenced by any observations; appeal allowed. (¶53-54)
In the Court's own words
Paragraph 51At this stage, we may refer to and rely upon one order of this Court in Vasant Nanaji Patre v. Vidarbha Irrigation Development Corporation & Ors., Civil Appeal No. 5305/2025. The appellant being dissatisfied by the award passed by the Collector filed a reference under Section 18 of the Act, 1894. The Reference Court passed an award enhancing the compensation. However, the respondents therein being aggrieved by the enhancement approached the High Court. The High Court reduced the compensation relying upon the award passed by the Lok Adalat in respect of other landowners. This Court set aside the judgment of the High Court to the extent it reduced the compensation with the following observations:- “7. In our considered opinion, the award passed by the Lok Adalat will be binding only on the parties, who entered into a settlement accepted by both sides. However, as the appellant did not agree to such a settlement and opted to pursue his legal remedy for enhancement of compensation in accordance with the provisions of the erstwhile Land Acquisition Act, 1894, he cannot be bound down with the compensation amount as agreed to by the other land owners. That being so, the award of the Lok Adalat could not be an exemplar to be followed by the High Court for the purpose of reducing the compensation awarded to the appellant. Faced with this, learned Senior Counsel for the respondents refers to the Sale Deed dated 25.03.1994 (Exhibit 22), which find mention in paras 15 and 16 of the impugned judgment of the High Court. As regard to the said exemplar, it may be seen that Section 4 Notification for acquiring the subject land was issued in the year 2000 whereas the aforementioned sale instance pertains to the year 1994. In that case, the High Court ought to have applied the annual escalation of not less than 10 to 12 per cent per annum, and then determine the market value of the acquired land. No such exercise has been undertaken in the instant case. It is also not clear from the facts on record as to whether the Sale Deed dated 25.03.1994 (Exhibit 22. is a part of the acquired area and/or abutting thereto.” (Emphasis supplied)
Acts & Sections
Land Acquisition Act, 1894Legal Services Authorities Act, 1987Code of Civil Procedure, 1908One judgment a day. That's the whole habit.
Read the full text of SINGAPOGU BABU RAO & ORS v. SPECIAL DEPUTY COLLECTOR (LAND ACQUISITION) & ORS — and get the Supreme Court's output as a five-minute daily read, with plain-language headnotes and the questions each judgment settles.
Create my free accountFree forever plan · 30 seconds · data stays in India
Open the full judgment →