Govt. of Tamil Nadu v. P.R. Jaganathan; 2025 INSC 1332 - Acquisition - Settlement - Art. 226 Constitution
Tamil Nadu Acquisition of Land for Industrial Purposes Act, 1997 - Section 7,12 -Sections 7(2) and 7(4) of the 1997 Act exhibit a laudable objective. They facilitate land owners or interested persons to negotiate and arrive at an agreement on the amount of compensation to be paid. Once such an agreement is arrived at, it becomes a concluded contract under Section 3 of the Indian Contract Act, 1872. The rights and liabilities of the parties would only be governed by the terms of the contract. Hence, a contract voluntarily entered into between the parties, shall not be disturbed by taking recourse to the statutory provisions, which are sought to be excluded by such contract. A party to a contract cannot be permitted to have recourse to two different modes, especially after having accepted the compensation under the contract without any demur or protest. It is not open to either of the parties to resile from the terms of the agreement arrived at. (Para 21)
Settlement -A settlement arrived at under the concerned statute cannot be allowed to be reopened or modified. (Para 24)
Constitution of India - Article 226 -The power under Article 226 of the Constitution of India is both discretionary and extraordinary. Unless circumstances so warrant, there shall not be any interference in a concluded contract. (Para 24)
Case Info
Case Details
- Case name: Government of Tamil Nadu v. P.R. Jaganathan & Ors.
- Neutral citation: 2025 INSC 1332
- Coram: Justice M. M. Sundresh; Justice Nongmeikapam Kotiswar Singh
- Judgment date: November 19, 2025
- Appeal: Civil Appeal (arising out of SLP (C) Nos. 12770-83 of 2020)
Holding
- A concluded compensation agreement under Section 7(2) and 7(4) of the 1997 Act bars recourse to statutory interest under Section 12.
- High Court’s direction awarding interest from Section 3(2) notice date to 18.08.2020 was set aside; appeals allowed.
Key Statutes and Citations
- Tamil Nadu Acquisition of Land for Industrial Purposes Act, 1997: Sections 7 and 12.
- Indian Contract Act, 1872: Contract finality principles.
- Leading cases invoked: N. Murugesan (2022) 2 SCC 25 on approbate/reprobate; Ranveer Singh (2016) 14 SCC 191; Sangappa Biradar (2005) 4 SCC 264; NOIDA v. Ravindra Kumar (2022) 13 SCC 468; State of Gujarat v. Daya Shamji Bhai (1995) 5 SCC 746; and settlement-finality cases like Nathani Steels (1995 Supp (3) SCC 324).
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