M/S. STEEL AUTHORITY OF INDIA LTD. versus S.U.T.N.I. SANGAM & ORS.

M/S. STEEL AUTHORITY OF INDIA LTD. versus S.U.T.N.I. SANGAM & ORS.

Awardees who accepted compensation without protest are not entitled to reference under s.18; limitation for filing reference is mandatory and cannot be relaxed by court; association may file writ petitions but not reference applications; statutory estoppel applies against State and Housing Board who participated without objection; procedural requirements for protest are not substantive unless prescribed; doctrine of promissory estoppel applies in appropriate cases.

Parties
Appellant: Steel Authority of India Ltd.; Respondents: S.U.T.N.I. Sangam & Ors.; Appellant: Managing Director, Tamil Nadu Housing Board
Jurisdiction
India
Judgment Date
29 July 2009
Procedural Posture
Civil Appeal / Supreme Court Final Judgment
Outcome
Appeal by Steel Authority of India Ltd. allowed; appeals by Tamil Nadu Housing Board dismissed.
Legal Topics
Compensation, Reference Proceedings, Limitation, Statutory Interpretation, Promissory Estoppel
Land Acquisition Constitutional Law Compensation Reference Proceedings Limitation Statutory Interpretation Promissory Estoppel

Case Brief

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Parties

Steel Authority of India Ltd.

Appellant

S.U.T.N.I. Sangam & Ors.

Respondents

Managing Director, Tamil Nadu Housing Board

Appellant

Procedural Posture

Civil Appeal / Supreme Court Final Judgment

Legal Issues

  1. 1 Whether awardees who received compensation without protest are entitled to reference under s.18 of Land Acquisition Act, 1894
  2. 2 Whether limitation period for filing reference application under s.18 can be relaxed
  3. 3 Whether association can file reference application for awardees

Ratio Decidendi

Awardees who accepted compensation without protest are not entitled to reference under s.18; limitation for filing reference is mandatory and cannot be relaxed by court; association may file writ petitions but not reference applications; statutory estoppel applies against State and Housing Board who participated without objection; procedural requirements for protest are not substantive unless prescribed; doctrine of promissory estoppel applies in appropriate cases.

Court Disposition

Appeal by Steel Authority of India Ltd. allowed; appeals by Tamil Nadu Housing Board dismissed.

Orders

  • Appeals by Steel Authority of India Ltd. allowed with no order as to costs.
  • Appeals by Managing Director, Tamil Nadu Housing Board dismissed with costs; counsel's fee assessed at Rs. 25,000/- each.