The Andhra Pradesh High Court has clarified that landowners seeking to challenge acquisition notifications under the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013, are strictly confined to the three statutory grounds enumerated in Section 15. This ruling reinforces procedural boundaries in land acquisition disputes and curtails demands for non-statutory disclosures.
Background & Facts
The Dispute
The appellants, 30 landowners from Chittoor District, challenged four acquisition notifications issued under Section 11 of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 (LARR Act). The State proposed to acquire 150 acres of land for constructing an airport at Kuppam Village. The appellants contended that they were denied critical information necessary to file meaningful objections, specifically regarding the suitability of the land, justification for public purpose, and the Social Impact Assessment Report.
Procedural History
- 16.08.2025: Four acquisition notifications issued by the District Collector under Section 11 of the LARR Act.
- 28.10.2025: Writ petition filed in the High Court seeking quashing of notifications and direction to furnish information.
- 24.10.2025: Single Judge dismissed the petition, holding that technical documents like environmental clearances were not required to be disclosed for objection purposes, but granted liberty to file objections within two weeks.
- 03.11.2025: Coordinate Bench issued interim directions: authorities must disclose total land extent and non-sensitive information within three days; appellants to file objections by 19.11.2025.
- 30.01.2026: Writ appeal heard on merits after counter-affidavits and reply-affidavits were filed.
Relief Sought
The appellants sought: (1) quashing of the acquisition notifications; (2) mandatory disclosure of technical sanctions, administrative approvals, and the Social Impact Assessment Report; and (3) an opportunity to file detailed objections based on full information.
The Legal Issue
The central question was whether landowners entitled to object under Section 15 of the LARR Act have a right to demand disclosure of technical documents such as environmental clearances, detailed project reports, or administrative sanctions, beyond the three grounds explicitly enumerated in the statute.
Arguments Presented
For the Appellant
The appellants, represented by K.S. Murthy, argued that without access to technical sanctions, environmental clearances, and the Social Impact Assessment Report, they could not meaningfully assess the three statutory grounds under Section 15. They relied on State of Haryana v. Sardar Singh and Union of India v. Rameshwar Prasad to assert that procedural fairness under Article 14 and 21 requires full transparency. They contended that the exemption from Social Impact Assessment was procedurally flawed and should be challenged separately.
For the Respondent
The Advocate General argued that Section 15 of the LARR Act is exhaustive in listing permissible grounds for objection. The State had already disclosed the total land extent and area, satisfying the first ground. The public purpose of an airport is self-evident under the doctrine of eminent domain. The exemption from Social Impact Assessment under Section 10-A was validly notified and unchallenged. Technical documents are not statutorily required to be disclosed for objection purposes, as confirmed by the single judge.
The Court's Analysis
The Court undertook a strict textual interpretation of Section 15(1) of the LARR Act, which limits objections to three grounds: (a) area and suitability of land, (b) justification for public purpose, and (c) findings of the Social Impact Assessment Report. The Court emphasized that the legislature deliberately confined the scope of objections to these three areas, indicating an intent to prevent fishing expeditions or delays through irrelevant demands.
"The objections shall be confined only to the aforesaid three grounds enumerated in Section 15 of the Act, as permitted by the legislation."
The Court held that the State had fulfilled its obligation under clause (a) by disclosing the total extent of land proposed for acquisition. Clause (b) was satisfied by the nature of the project - an airport - whose public purpose is inherent and well-established under constitutional doctrine. Regarding clause (c), the Court noted that the Government had validly invoked Section 10-A to exempt the project from Social Impact Assessment, and the appellants had not challenged that exemption. Therefore, no obligation arose to furnish a report that does not exist.
The Court explicitly rejected the argument that technical documents such as environmental clearances or detailed project reports are necessary for filing objections. These are administrative or technical prerequisites for project approval, not statutory conditions for objection under Section 15. The learned single judge’s view was affirmed: such disclosures fall outside the statutory framework and cannot be compelled under writ jurisdiction.
The Court further observed that the appellants had already submitted objections in compliance with the interim order, and were granted further liberty to file additional objections by 02.02.2026, ensuring their procedural rights were preserved within the statutory limits.
The Verdict
The appellants’ writ appeal was dismissed. The Court held that Section 15 of the LARR Act limits objections to three specified grounds, and authorities are not obligated to disclose technical or administrative clearances beyond those grounds. The State’s disclosure of land extent satisfied statutory requirements, and the exemption from Social Impact Assessment was valid and unchallenged.
What This Means For Similar Cases
Objections Are Statutorily Constrained
- Practitioners must limit objections under Section 15 to the three enumerated grounds only; attempts to expand objections to include environmental clearances, feasibility studies, or financial viability will be rejected.
- Landowners cannot use writ petitions to compel disclosure of documents not mandated by the LARR Act.
Exemption Under Section 10-A Is Binding Unless Challenged
- When a project is exempted from Social Impact Assessment under Section 10-A, the absence of the report cannot be used to invalidate acquisition notifications.
- Any challenge to the exemption itself must be filed as a separate writ petition; it cannot be raised as a collateral attack in objections under Section 15.
Procedural Fairness Is Preserved Within Statutory Bounds
- Authorities must disclose the extent and location of land proposed for acquisition - this is mandatory.
- Liberty to file objections must be granted, but only on the three statutory grounds. Courts will not extend this right to non-statutory disclosures.
- Practitioners should advise clients to file objections promptly on the three grounds, even if full technical data is unavailable, as failure to do so may bar future challenges.
