SC Enhances Compensation in 1990s Jintur MIDC Acquisition

The Supreme Court has enhanced the compensation payable to a group of landowners from Parbhani district whose land was acquired three decades ago for the establishment of an MIDC industrial area near Jintur, raising the rate from Rs 32,000 to Rs 58,320 per acre while extending all statutory benefits under the Land Acquisition Act, 1894. Court, however, clarified that the landowners will not be entitled to interest for the period of delay in filing their appeals.

A bench of Chief Justice of India B R Gavai (since retired) and Justice K Vinod Chandran set aside both the 2007 decision of the Reference Court and the 2022 judgment of the Bombay High Court (Aurangabad Bench), which had upheld the lower compensation.

The Supreme Court noted that it had already awarded enhanced compensation to another set of landowners in July 2025 in Manohar & Others v State of Maharashtra, arising from the same acquisition process and the same common High Court decision. The present appellants, it held, stood on identical footing.

The case concerns agricultural lands acquired in the early 1990s for the Jintur Maharashtra Industrial Development Corporation (MIDC) project under the Maharashtra Industrial Development Act, 1961. A notice under Section 32(2) was issued on January 16, 1992, and possession was taken on December 6, 1994. The Land Acquisition Officer quantified total compensation at Rs 45.70 lakh for an area of 89.44 hectares. The landowners accepted the amount under protest and moved a reference under Section 18 of the Land Acquisition Act in 1997.

In June 2007, the Reference Court partly enhanced compensation. But in April 2022, a single judge of the High Court dismissed the landowners’ appeals and affirmed the lower award. This prompted the present batch of petitions before the Supreme Court.

Before the bench, the landowners argued that the court’s judgment in Manohar squarely applied because the acquisition, evidentiary record and sale exemplars were the same. They submitted that denying them parity would result in discriminatory treatment of landowners whose cases arose from the same notification.

The State and the MIDC opposed the plea and claimed that the appellants’ lands were farther from Jintur town and therefore required higher deductions.

Court rejected the MIDC’s contention after turning to the High Court’s own factual findings in paragraph 46 of the 2022 judgment. The High Court had recorded that the acquired lands were “adjacent to Jintur town,” were closer to Jintur than to nearby Pungala, had access to sufficient water from a percolation tank situated opposite the land, abutted the Nashik–Nirmal State Highway, and possessed non-agricultural potential. The High Court had also noted that the claimants’ evidence on proximity and suitability for industrial development had not been challenged in cross-examination.

Given these findings, the Supreme Court held that the argument of the MIDC that the lands were 5 km away from Jintur could not stand. Most of the land, the bench noted, was either irrigated or lay adjacent to the highway, reinforcing the earlier conclusion that it was prime land suitable for industrial development.

Applying its reasoning in Manohar, court accepted the highest sale exemplar from March 31, 1990, which reflected a market value of Rs 72,900 per acre. It applied a 20 per cent deduction, used earlier to account for the difference between small-plot sale deeds and bulk acquisition, arriving at a final rate of Rs 58,320 per acre.

Allowing all the appeals, court quashed the 2022 High Court judgment and the 2007 Reference Court award, directed the enhancement of compensation to Rs 58,320 per acre, and ordered payment of all consequential benefits under Sections 23(1-A), 23(2) and 28 of the Land Acquisition Act, 1894, while denying interest for the period of delay in approaching the Court.

Case Title: Ashok s/o Vitthalrao Jagtap Vs The State of Maharashtra and Ors

Judgment Date: November 18, 2025

Bench: Chief Justice of India B R Gavai (since retired) and Justice K Vinod Chandran