Nandi Infrastructure Corridor Enterprises Ltd. v. B. Gurappa Naidu 2026 INSC 434 - Art.227 Constitution - Supervisory Jurisdiction - Scope
Supervisory jurisdiction is not to correct every error of fact or even a legal flaw when the final finding is justified or can be supported.
Constitution of India - Article 227 - a) The power of superintendence under Article 227 is not to be exercised unless there has been an (a) unwarranted assumption of jurisdiction, not vested in Court or tribunal, or (b) gross abuse of jurisdiction or (c) an unjustifiable refusal to exercise jurisdiction vested in Courts or tribunals. b) The High Court while acting under this Article cannot exercise its power as an appellate court or substitute its own judgment in place of that of the subordinate court to correct an error, which is not apparent on the face of the record. c) The High Court exercising supervisory jurisdiction does not act as a court of first appeal to reappreciate, reweigh the evidence or facts upon which the determination under challenge is based. Supervisory jurisdiction is not to correct every error of fact or even a legal flaw when the final finding is justified or can be supported. The High Court is not to substitute its own decision on facts and conclusion, for that of the inferior court or tribunal. (Para 35)
Practice and Procedure - The executive cannot be allowed to explain away or reinterpret a statutory instrument during the course of litigation to the prejudice of one of the parties. (Para 36.3.2)
Compromise Decree- In the absence of any stipulation regarding interest in a compromise decree, a party cannot claim interest as a matter of right. (Para 39.3)
Case Info
Basic Case Information
Case name: Nandi Infrastructure Corridor Enterprises Ltd. & Anr. v. B. Gurappa Naidu & Ors.Neutral citation: 2026 INSC 434Court: Supreme Court of India, Civil Appellate JurisdictionCoram: Justice Aravind Kumar and Justice N.V. AnjariaJudgment date: 30 April 2026 (as noted at the end of the judgment)
Case Laws & Citations Referred
- Shalini Shyam Shetty and Another v. Rajendra Shankar Patil, (2010) 8 SCC 329
- Jodhey v. State, AIR 1952 All 788
- Mani Nariman Daruwala @ Bharucha (deceased) through LRs & Ors. v. Phiroz N. Bhatena & Ors., (1991) 3 SCC 141
- Chandavarkar Sita Ratna Rao v. Ashalata S. Guram, (1986) 4 SCC 447
- Waryam Singh v. Amarnath, AIR 1954 SC 215
- Nagendra Nath Bora & Another v. The Commissioner of Hills Division & Others, AIR 1958 SC 398
- Estralla Rubber v. Dass Estate (P) Ltd., (2001) 8 SCC 97
- Garment Craft v. Prakash Chand Goel, (2022) 4 SCC 181
- K.S. Shivadevamma and Others v. Assistant Commissioner and Land Acquisition Officer and Another, (1996) 2 SCC 62
- Government of Tamil Nadu v. P.R. Jaganathan & Others, 2025 SCC OnLine SC 2496
(Plus earlier orders in the same matter: SLP (C) No. 10633 of 2012; CRP No. 166 of 2010; W.P. Nos. 21068/2012, 25158/2012, etc.)
Statutes / Legal Provisions Referred
- Constitution of India, Article 227 (supervisory jurisdiction of High Courts)
- Code of Civil Procedure, 1908, Section 89 (settlement/compromise incorporated in decree)
- Karnataka Stamp Act, 1957 (guideline value / valuation for stamp duty)
- Karnataka Government Notification dated 17.04.2007 prescribing guideline values and Special Instructions (particularly Instructions 1, 2 and 6)
- Land acquisition/valuation jurisprudence is discussed via K.S. Shivadevamma, though not a statute itself
Three‑Sentence Brief Summary
The Supreme Court held that the Karnataka High Court exceeded its limited supervisory jurisdiction under Article 227 by re‑appreciating the Executing Court’s determination of guideline value and by effectively substituting its own interpretation of the State’s 17.04.2007 valuation notification. Restoring the Executing Court’s order, the Court fixed the value of the AA Schedule property at Rs. 1,000 per square foot (total Rs. 13,72,14,000), holding that the specific BBMP/municipal‑area rate (Rs. 800 plus 25% for State Highway abutment) applied and that the residual 50% industrial‑land reduction under Instruction 6 was inapplicable. Consequently, Nandi Infrastructure Corridor Enterprises (N.I.C.E.) must pay the balance amount of Rs. 8,79,95,250 with interest at 6% per annum as directed earlier in W.P. No. 25158 of 2012, subject to any outcome of proceedings against that interest order.
