The Supreme Court recently used its extraordinary powers under Article 142 of the Indian Constitution to ensure complete justice between parties involved in land acquisition cases. This decision was based on the principles established in the Indore Development Authority v. Manoharlal case. Various groups of appeals were categorized and specific directions were given based on their circumstances.
Principles Applied
- Exception to Doctrine of Merger: The Court noted that Article 142 of the Constitution grants exceptional powers to ensure complete justice, which can override the doctrine of merger and the rule of stare decisis.
- Indore Development Authority v. Manoharlal: The test laid down in this case was applied to determine the outcome of the appeals filed by landowners.
- Res Judicata: The court clarified that previous decisions may not always apply as res judicata, especially when larger public interests are involved.
- Suppression of Material Facts: The deliberate withholding of material facts was discussed, highlighting that it must be of such critical importance that their absence would render any decision unjust.
Issues Considered
- Whether the dismissal of appeals in the first round bars subsequent appeals.
- If suppression of facts constitutes a material issue.
- The applicability of the Doctrine of Merger.
- The rights of subsequent purchasers in disputes.
Directions Given
- Fresh acquisition proceedings initiated for certain groups.
- Appeals rendered infructuous for some groups.
- Certain appeals allowed due to specific circumstances.
- Remittance of cases to the High Court for further adjudication.
- Separate adjudication for specific cases scheduled for July 2024.
Multiple Choice Questions (MCQs):
- What exceptional power did the Supreme Court use to ensure complete justice in the land acquisition cases?
- A) Article 32
- B) Article 136
- C) Article 142
- D) Article 226
- Which test was applied by the Supreme Court to determine the outcomes of the appeals filed by landowners?
- A) Doctrine of Merger test
- B) Res Judicata test
- C) Test laid down in Indore Development Authority v. Manoharlal
- D) Stare Decisis test
- What did the Supreme Court clarify regarding the suppression of material facts?
- A) It must always lead to outright dismissal of appeals.
- B) It must be of minimal importance to affect the decision.
- C) It requires deliberate withholding of critical facts.
- D) It is irrelevant in the adjudication process.