Land acquisition references: company participation is limited, and conflicting Supreme Court rulings should be followed by better reasoning.

In land acquisition references, the acquiring company's statutory right under Section 50(2) to appear and adduce evidence on compensation does not automatically confer a right to be impleaded as a party under Order I Rule 10. The Court's procedural powers under Section 53 of the Land Acquisition Act operate subject to the Act, and impleadment is treated as distinct from the limited right of participation in compensation proceedings. Where Supreme Court decisions of co-equal Benches conflict, the later decision is not followed merely because of chronology; the High Court should prefer the ruling that is more accurately reasoned and more fully states the law.

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Issues: (i) Whether a company for whose benefit land is acquired can be impleaded as a party in a reference under Section 18 of the Land Acquisition Act, 1894. (ii) When two decisions of the Supreme Court rendered by co-equal Benches are in direct conflict, which decision should be followed by the High Court.

Issue (i): Whether a company for whose benefit land is acquired can be impleaded as a party in a reference under Section 18 of the Land Acquisition Act, 1894.

Analysis: The majority held that the company is not merely entitled to appear and adduce evidence under Section 50(2), but is also a person interested for the limited purpose of participating in the compensation reference. The Civil Procedure Code applies to proceedings before the Court under Section 53, subject to inconsistency with the Act, and there is no inconsistency between Section 50(2) and Order I Rule 10. Section 50(2) limits the company's role to evidence on compensation, while the proviso only bars the company from demanding a reference under Section 18. That bar does not extend to impleadment once the matter is before the Court on a landowner's reference.

Conclusion: The company can be impleaded as a party in the reference proceedings.

Issue (ii): When two decisions of the Supreme Court rendered by co-equal Benches are in direct conflict, which decision should be followed by the High Court.

Analysis: The majority held that a High Court is not bound to follow the later decision merely because it is later in time. Where two co-equal Bench decisions of the Supreme Court directly conflict, the Court must follow the decision that appears to state the law more accurately and more elaborately. The decisive consideration is the correctness and reasoning of the competing rulings, not chronology alone.

Conclusion: The High Court should follow the decision that appears to be more accurate in law and better reasoned, not automatically the later one.

Final Conclusion: The revision petitions were dismissed on the majority view that the company had no right to be impleaded as a party in the land acquisition reference, though it retained the statutory right to appear and adduce evidence on compensation.

Ratio Decidendi: In a land acquisition reference, the acquiring company's statutory right to appear and adduce evidence under Section 50(2) does not by itself confer a right to be impleaded as a party under Order I Rule 10; and where Supreme Court decisions of co-equal strength conflict, the decision that is more accurately reasoned should be followed.

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