Thursday, July 9, 2026

Chief Justice Meenakshi Madan Rai, Justice Soni Srivastava upholds judgement by Justice Rajiv Roy in case of land acquistion for Bharatmala Patna-Sahebganj corridor from Bakarpurhat to Manikpur, Muzaffarpur

In Ashok Rai @ Ashok Ray Son of Late Rajendra Ray & Ors. vs.  The Union of India through the Secretary, Ministry of Road Transport and Highway & Ors. (2026), Patna High Court's Division Bench of Justices Meenakshi Madan Rai and Soni Shrivastava delivrered a 14-page long judgement dated June 24, 2026, wherein, it concluded:"we find that the impugned Judgment and Order dated 13.03.2026, of the learned Single Judge in Civil Writ Jurisdiction Case (C.W.J.C) No. 19292 of 2024) warrants no interference. Consequently, this LPA stands dismissed and disposed of." The judgement was authored by Chief Justice Rai. It is one of the 39 judgments delivered by her Division Bench upon joining the High Court as its 48th Chief Justice on June 5, 2026. During her brief tenure she authored 791 orders besides some 40 judgements.  

In Ashok Rai @ Ashok Ray Son of Late Rajendra Ray & Ors. vs.  The Union of India through the Secretary, Ministry of Road Transport and Highway & Ors. (2026), Justice Rajiv Roy of Patna High Court passed a 14-long order dated March 13, 2026, wherein, he concluded:"25. The petitioners who chose not to file any objection and sat over the matter are themselves to be blamed. It is further clear that knowingly, they suppressed this fact about the second notification while invoking the writ jurisdiction. The petition/representation claim to have been filed is/are belatedly in the year 2023 after the final notification was published on 14.06.2022. 26. Considering the aforesaid facts and taking into account the submissions/documents on record, this Court can only record that now that the land in question stands acquired and ‘the MOTH’ has taken the due legal process before issuance of the notification dated 14.06.2022, the petitioners if so want can take steps for getting the compensation amount inaccordance with law after showing their bona fide for the land that stands acquired. 27. So far as the writ petition is concerned, it is devoid of any merit and is accordingly dismissed. The interim protection granted to the petitioners stands vacated."

The other six respondents were: Chief General Manager, National Highway Authority of India, Regional Office, Regional Director, National Highway Authority of India, Regional Office, Patna, Project Director, National Highway Authority of India, Motihari, District Land Acquisition Officer, Muzaffarpur, District Magistrate, Muzaffarpur. 

The appellants by filing the L.P.A had assailed the judgment by Justice Roy by which the writ petition was dismissed concluding that it was devoid of merit. The appellants seek the setting aside of the impugned Judgment. 2. The appellants’/petitioners’ case was that, vide Notification No. 2456(E) dated June 22, 2021 the Ministry of Road Transport and Highways (MORTH) declared its intention to acquire the lands detailed in the Schedule thereto for building, maintenance, management and operation of Bharatmala Patna-Sahebganj corridor (Adalwari-Manikpur Section) ending in the stretch of land from Bakarpurhat to Manikpur, District-Muzaffarpur. The Notification was published in the Hindi newspaper Prabhat Khabar and Hindustan, both dated July 10, 2021 and Dainik Bhaskar and Times of India, both on December 1, 2021. Necessary measurements were undertaken and map prepared. Pursuant to such steps, objections were raised by some stakeholders, which were considered but disallowed by the competent authority. Subsequent thereto, the MORTH issued another Notification, dated June 14, 2022, bearing No. 2724(E), declaring its intention to acquire lands specified in the annexed Schedule. The appellants had submitted that the second Notification indicated an alteration in the acquisition of the lands, vide which the earlier alignment was deviated by about 400 feet allegedly to favour the owner of the ‘Blue Lotus’ Hotel. By such deviation, only a small portion of the property of ‘Blue Lotus’ Hotel, would be acquired, but a larger area of the appellants’ property would be taken thereby infringing on the property rights of the appellants. 

The contention of the counsel for the appellants is that on publication of the first Notification, the map regarding acquisition was prepared which proposed a straight alignment, for the formation of the four lane highway to minimize, and ensure equal distribution of acquisition on both sides of the existing road. However, subsequently without any technical justification or prior notice to the appellants, the alignment was altered exclusively as already agitated. Such realignment shifted the entire burden on to the appellants’ land and livelihood. Relying on Dev Sharan and Others vs. State of Uttar Pradesh and Others  (2011) 4 SCC 769, it was submitted that the Hon’ble Supreme Court has observed therein that, Section-5A of the Land Acquisition Act, 1894, embodies a very just and wholesome principle of giving proper and reasonable opportunity to a landuser of persuading the authorities that his property should not be acquired. That, Section-5A has to be read in tandem with the provisions of Article 300A of the Constitution of India. It is next put forth that, despite the appellants having approached the concerned competent authorities on the matter, no steps were initiated. It is contended that the impugned Judgment of the Single Judge, erroneously held that the appellants were at fault for not objecting to the Notification of 2021, when in fact no reason arose for the appellants to object to the said Notification, as it did not infringe upon their rights. That, the injury to the appellants was only caused by the subsequent clandestine re-measurement and revised map. 

The counsel also submitted that the finding of the Single Judge that non-joinder of ‘Blue Lotus’ Hotel owner is fatal, is legally flawed. On this count, strength was drawn from the decision in Smt. Savita Garg vs. The Director, National Heart Institute (2004) 8 SCC 56, wherein the Supreme Court held that so far as the law with regard to non-joinder of necessary party under the Civil Procedure Code (CPC) Order 1 Rule 9 and Order 1 Rule 10, lays down that no suit shall fail because of mis-joinder and non-joinder of parties. In any event the Court has the power under Order 1 Rule 10(4) to give directions to implead a person who is a necessary party. That, no such direction was given by the Single Judge. 

The counsel for the respondents walked the High Court through the provisions of Section 3A, 3C and 3D of the National Highways Act, 1956, and emphasized that it provides for as follows; Section 3A vests the Central Government with power to acquire land for public purpose, for construction of National Highway and to declare its intention a notification with description of land is to be published in the Official Gazette; Section-3C provides for hearing of objection raised by any person aggrieved by such acquisition and the competent authority has the discretion to allow or disallow the objection; Section-3D provides for declaration of acquisition and the purpose of such acquisition by 2 (2004) 8 SCC 56 publication of the declaration in newspapers. That it is specifically provided that once a declaration is made by the Central Government, it shall not be called into question by any Court or by any other authority. It was next contended that one two-lane Railway Under Bridge (RUB) was already in existence and another was proposed to be constructed. Since a mandatory distance was required to be maintained between the two Railway Under Bridges, the realignment of the road was proposed for that purpose. 

Drawing strength from the decision in Union of India vs. Kushala Shetty and Ors.,2011) 12 SCC 69, it was canvassed that judicial review has a narrow scope and that the decision to alter any alignment as part of National Highways is a policy decision within the clear domain of the Central Government. 8. The allegations pertaining to mala fides are without any specific reasons assigned to the allegations and the contention that a change in the alignment will benefit a party is baseless, in the absence of specific materials to show the mala fides. To that extent, reliance was placed on the decision of the Supreme Court rendered in the case of E.P. Royappa vs. State of Tamil Nadu and Anr(1974) 4 SCC 3,wherein, it was observed that the 3 (2011) 12 SCC 69 4 (1974) 4 SCC 3 burden of establishing malafides is very heavy on the person who alleges it. The alteration of the alignment by the competent authority, was in line with the objectives of the Bharatmala Project, sans influence of any land owner. That, at the time when the DPR was submitted for approval at the headquarters of the NHAI, there was no Railway Under Bridge (RUB) nor were there Railway tracks, hence, the consultant had no occasion to inquire from the Railways. Based on the approved Letter of Award of Contract (LAC), dated May 18, 2020, the first Gazette Notification dated 21.06.2021 was issued, however, after the DPR consultant learned of the RUB construction while taking data on the field for 3D notification, the realignment took place to include the RUB, pursuant to which the Gazette Notification dated June 14, 2022 came to be published. 

Chief Justice Rai observed: "The entire process has been carried out in a fair manner. The order of the learned Single Judge thereby warrants no interference." She added:"11. In our considered view, it is appropriate to point out that the law relating to the exercise of Intra Court Jurisdiction has been laid down by a Division Bench of the Supreme court in the case of Management of Narendra & Company Private Limited vs. Workmen of Narendra & Company  (2016) 3 SCC 340: 

The Supreme Court has held that:- “5……………………… Be that as it may, in an intra-court appeal, on a finding of fact, unless the Appellate Bench reaches a conclusion that the finding of the Single Bench is perverse, it shall not disturb the same. Merely because another view or a better view is possible, there should be no interference with or disturbance of the order passed by the Single Judge, unless both sides agree for a fairer approach on relief.” 

Chief Justice Rai observed: "12. That, having cleared the cloud on Intra-Court Appeals, after examining the pleadings and considering the arguments advanced before us, in our considered view the appellants have firstly failed to establish the mala fides against the concerned authorities, for the purpose of benefiting the owner of the ‘Blue Lotus’ Hotel. Although, the learned counsel for the appellants hastened to point out to the Court, during the arguments advanced that no specific mala fides were alleged in the averments, however, we are inclined to agree with the submissions of the learned counsel for the respondents, that, the suggestion that the road was being realigned for the benefit of ‘Blue Lotus’ Hotel is sufficient to insinuate mala fides which is without substantiation. The submission on the facet of mala fides deserves to be and is accordingly, disregarded. 13. While considering the aspect on issuance of Notifications, the appellants concedely have no argument with regard to the first Notification. The grievance of the appellants is confined to the second Notification, dated 14.06.2022, which alleged was issued sans notice and to their prejudice. This submission cannot be countenanced for the fact that, the Notification was issued in the Government Gazette, which is an official legal process designed to bring inter alia administrative decisions into the public domain. Such publication is deemed sufficient notice to all interested parties fulfilling the requirements of transparency and in addition to the above it gives legal authority to governmental action including land acquisition." 

The judgedment reads: "14. On this facet strength is garnered from Union of India and Others Vs. Ganesh Das Bhojraj 2000 SCC OnLine SC 438, paragraph 14 which provides as follows; “14. From the aforesaid judgment it can be stated that it is an established practice that the publication in the Official Gazette, that is, the Gazette of India (sic is an) ordinary method of bringing a rule or subordinate legislation to the notice of the persons concerned. Individual service of a general notification on every member of the public is not required and the interested person can acquaint himself with the contents of the notification published in the Gazette. It is the usual mode followed since years and there is no other mode prescribed under the present statute except by the amendment in the year 1998 by Bill 21 of 1998.” 

Notably, reliance was also placed on Viraj Impex Pvt. Ltd. Vs. Union of India and Anr., 2026 SCC OnLine SC 101, wherein at paragraph 16 the Supreme Court observed: “16. The requirement of publication in the gazette, therefore, serves a dual constitutional purpose, i.e. (a) it ensures accessibility and notice to those governed by the law, and (b) it ensures accountability and solemnity in the exercise of delegated legislative power. The requirement of publication in the gazette, is therefore not an empty formality. It is an act by which an executive decision is transformed into law. It is precisely for this reason that courts have consistently insisted that strict compliance with the publication requirements is a condition precedent for the enforceability of delegated legislation.” 

In the penultiumate paragraph of the judgement, the Division Bench observed: "16. Ignorance of publication of such Notification, cannot be a ground to demolish the case of the respondents. 17. Indeed, while agreeing with the submission of the appellants that they had no reason to object to the first Notification, as it appears that the objections raised by other stakeholders were considered but disallowed by the respondents, it is apposite to notice that the Statement of Objects and Reasons of the National Highway Act, 1956 inter alia mentions therein that Parliament has exclusive powers of legislation with respect to Highways which are declared to be National Highways as proper development of road infrastructure is essential for economic development of the country. 18. Section-3A and 3C of the National Highways Act, 1956 as already discussed herein, also lays down the powers of the Central Government to acquire land where it is satisfied that for public purpose, any land is required for the building, maintenance, management or operation of National Highway or part thereof. The requirement of such intention is to be notified in the Official Gazette. Should objections be filed before the competent authority, it shall after hearing the objections and making further inquiries, may by order, either allow or disallow the objection. It is no one’s case that Notifications to acquire the property were not published, in the obtaining facts the respondents cannot be foisted with the responsibility of the lack of awareness of the appellants. We also cannot fault the observation of the learned Single Judge regarding non impleadment of the ‘Blue Lotus’ Hotel. It was for the appellants to have either sought for impleadment of the said Hotel as a respondent to the petition or mentioned it before the Court to enable the Court to take appropriate steps. In any event, it was for the petitioner to have ensured impleadment of the party as no order can be issued behind the back of a party who is unaware of the Court proceedings, the decision of which would likely affect it." 



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