Supreme Court Holds 1894 Act Governs Compensation for Pre-2015 NH Act Awards

Case Snapshot

• Case Name: Manav Bhanot v. National Highway Authority of India

• Citation: 2026 INSC 973 (Reportable)

• Bench: Justice J.B. Pardiwala and Justice K. Vinod Chandran

• Date of Judgment: September 8, 2026

• Area of Law: Land Acquisition, Compensation, National Highways Act, Solatium, Interest

The Judgment in One Line

Supreme Court holds that solatium and interest for NH Act acquisitions must be computed under the 1894 Act if the Competent Authority's award was passed before January 1, 2015.

Why This Judgment Matters

This judgment clarifies the crucial question of which compensation regime applies to land acquisitions under the National Highways Act—the old Land Acquisition Act, 1894 or the new Right to Fair Compensation Act, 2013. It establishes that the date of the Competent Authority's award under Section 3G of the NH Act, not the Arbitrator's award, determines the applicable compensation regime. The ruling resolves a significant ambiguity arising from the Tarsem Singh trilogy and provides certainty for landowners and acquiring authorities regarding solatium and interest calculations.

Background

Land was acquired under the National Highways Act for the NHAI. The Section 3A notification was published in June-July 2011. The declaration under Section 3D was published in January 2012. The Competent Authority determined compensation under Section 3G on Jul

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