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Case Analysis Sanjaybhai Manubhai Patel & Ors vs Competent Authority National Highway Authority of India and Deputy Collector Navsari (Expressway) & Ors C/SCA/3720/2026
Synopsis
This judgment by a Division Bench of the Gujarat High Court allows a writ petition filed by landowners seeking the benefit of additional compensation under Section 30(3) of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 (RFCTLARR Act). The petitioners' land was acquired under the National Highways Act, 1956, and the award had determined the market value by applying the multiplication factor of 2 under Section 26(2) of the 2013 Act. However, the benefit of 12% additional compensation under Section 30(3) was calculated only on the base market value (under Section 26(1)) and not on the enhanced value after applying the multiplication factor. Following its earlier decisions, the court held that the additional compensation under Section 30(3) must be computed on the market value as determined under Section 26, which includes the multiplication factor. The petition was partly allowed, and directions were issued to grant the additional compensation on the enhanced market value along with interest, while the prayer for benefits under Schedules II and III was rejected due to delay.
1. Proper Heading for the judgment
Citation: Sanjaybhai Manubhai Patel & Ors. v. Competent Authority, National Highway Authority of India and Deputy Collector, Navsari (Expressway) & Ors., R/Special Civil Application No. 3720 of 2026, decided on 24.03.2026 (Gujarat High Court - DB)
Coram: Hon'ble The Chief Justice Mrs. Sunita Agarwal and Hon'ble Mr. Justice D.N. Ray (Division Bench)
Core Law: Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013; National Highways Act, 1956.
Gujarat High Court holds that additional compensation under Section 30(3) of RFCTLARR Act must be computed on market value determined under Section 26 including multiplication factor, not just base value.
2. Legal framework
This judgment interprets key provisions of the RFCTLARR Act, 2013, in the context of land acquisition under the National Highways Act, 1956.
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