Synopsis

The petitioners, whose agricultural lands were acquired for a medium irrigation project, filed applications under Section 64 of the Right to Fair Compensation Act, 2013 seeking reference for enhancement of compensation. Their applications were delayed by 17 to 18 days beyond the six‑week period prescribed under Section 64(2). The Deputy Collector (Land Acquisition) rejected the applications on the ground of delay. The petitioners filed writ petitions challenging the rejection. The Bombay High Court allowed the writ petitions, holding that the Collector has discretionary power under the last proviso to Section 64(2) to condone delay of up to one year if sufficient cause is shown. The court found that the delay was minimal, the petitioners were farmers from an Adivasi region, the COVID‑19 pandemic had disrupted normal life, and the reasons given were justifiable. The court directed the Collector to entertain the reference applications, but ordered that the petitioners shall not be entitled to any interest for the delayed period.

Court: High Court of Judicature at Bombay, Bench at Aurangabad

Coram: Justice Ajit B. Kade thankkar

Date of Judgment: 1st April 2026

Citation: Writ Petition No. 13020 of 2024 (and connected matters)

Core Law: Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 – Section 64 (reference to Authority for enhancement of compensation)

2. Legal Framework

Major laws and provisions involved

• Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 – Section 23 (enquiry and award by Collector), Section 64 (reference to Authority for determination of compensation)

• Constitution of India – Article 14 (right to equality), Article 300A (right to property)

Key legal principles applied

• Discretion of Collector to condone delay under Section 64(2): The last proviso to Section 64(2) empowers the Collector to entertain an application for reference even after the expiry of the initial six‑week period, within a further period of one year, if satisfied that there was sufficient cause for not filing it within the prescribed period.

• Sufficient cause – liberal interpretation in land acquisition matters: The court held that “satisfaction on sufficient cause” is a relative concept and must be applied pragmatically, considering the ground reality of farmers, especially during the COVID‑19 pandemic. The Collector, being the guardian of farmers’ interests in the district, must

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