Introduction
In a significant decision impacting numerous land acquisition cases in Maharashtra, the Supreme Court has enhanced the compensation payable to landowners whose land was acquired for the Jintur MIDC project. The Court applied the principle of parity, extending to the present appellants the same benefits already granted to similarly placed landowners in the earlier Manohar v. State of Maharashtra case (2025).
Background of the Case
The land parcels belonging to the appellants were acquired in the early 1990s under the Maharashtra Industrial Development Act, 1961 for establishing an industrial area near Jintur town in Parbhani district.
- Notification: Section 32(2) MIDC Act – 1992
- Award: December 1994 – Compensation of ₹45.70 lakhs (total)
- Reference under Section 18 LA Act: 1997
- Reference Court (2007): Enhanced compensation
- Bombay High Court (2022): Dismissed landowners’ appeals
Dissatisfied with the High Court decision, the landowners approached the Supreme Court.
Key Issue Before the Supreme Court
Whether the appellants, whose lands were acquired for the same MIDC project, are entitled to the same enhanced compensation granted in Manohar & Others v. State of Maharashtra (2025), despite minor location-based distinctions claimed by the State.
Supreme Court’s Analysis
The Court rejected the State’s contention that the lands were situated far from Jintur town. Referring to factual findings of both the Reference Court and the High Court, it noted:
- The acquired lands are adjacent to Jintur town.
- The location is close to the Nashik–Nirmal State Highway (T-point).
- Several parcels have irrigation facilities and non-agricultural potential.
- Documentary evidence (village map, Jintur map) supported proximity and suitability for industrial use.
The Court held that the present landowners are similarly situated to those in the Manohar case, where:
- Highest sale exemplar (1990) showed ₹72,900 per acre.
- Court applied 20% deduction for small-plot exemplars.
- Final rate applied: ₹58,320 per acre.
Final Order of the Supreme Court
The Supreme Court allowed the appeals and passed the following directions:
1. Compensation Enhanced
- From ₹32,000 per acre to ₹58,320 per acre.
2. Consequential Benefits
- Solatium and interest granted under Sections 23(1-A), 23(2), and 28 of the Land Acquisition Act, 1894.
- No interest allowed for the period of delay in filing the SLP, as earlier ordered.
3. Impugned Judgments Set Aside
- High Court judgment (April 21, 2022) and Reference Court judgment (June 7, 2007) quashed.
Impact of the Judgment
This ruling has wider implications for landowners affected by the Jintur MIDC acquisition and similar industrial development acquisitions:
- Ensures uniformity in compensation for similarly placed landowners.
- Reinforces the principle of parity in land acquisition awards.
- Clarifies that proximity and potentiality of land must be assessed objectively, not based on mere claims.
Conclusion
The Supreme Court’s judgment reaffirms fairness in land acquisition compensation and ensures that landowners receive equitable treatment. By aligning the present case with the earlier Manohar ruling, the Court has brought consistency and justice to long-pending acquisition disputes related to the Jintur MIDC project.
Ashok s/o Vitthalrao Jagtap v. State of Maharashtra & Others, decided on : 18-11-2025