Civil court jurisdiction barred in land acquisition challenges; injunction unavailable after possession was taken and handed over.

The Land Acquisition Act, 1894 was treated as a complete code for acquisition proceedings, so once the Section 4(1) notification and Section 6 declaration were published, the process crystallised and later statutory stages could follow. Civil court jurisdiction under Section 9 CPC was held excluded by necessary implication for challenges to the legality of the notification and declaration, with such objections available only under Article 226. Because possession had already been taken and handed over, the trial court lacked jurisdiction to grant interim injunction. The civil suit was therefore not maintainable, and the injunction orders were without jurisdiction and unsustainable.

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Issues: Whether a civil suit was maintainable to question the validity of acquisition proceedings under the Land Acquisition Act, 1894, and whether interim injunction could be granted in the face of completed acquisition and taken possession.

Analysis: The Land Acquisition Act, 1894 was treated as a complete code for acquisition of land for public purpose. Once notification under Section 4(1) and declaration under Section 6 were published, the acquisition process stood crystallised, and the State could proceed through the statutory stages, including notice under Section 9 and taking possession in the manner contemplated by the Act. The judgment held that the civil court's jurisdiction under Section 9 of the Code of Civil Procedure, 1908 stood excluded by necessary implication in matters questioning the legality of the notification and declaration, such challenge being open only in proceedings under Article 226 of the Constitution of India. Since possession had already been taken and handed over, the trial court had no jurisdiction to grant an injunction.

Conclusion: The civil suit was not maintainable, and the injunction orders were without jurisdiction and unsustainable.

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