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Issues: Whether the inquiry under section 5A of the Land Acquisition Act, 1894 is a quasi-judicial inquiry or an administrative inquiry.
Analysis: The scheme of the Act shows that a notification under section 4 is only a preliminary step, while the decisive satisfaction for acquisition is reached by the Government under section 6. The inquiry under section 5A is intended to inform the Government and to afford objectors an opportunity to place relevant material before it. The statute permits the Collector to make further inquiry and submit his report with recommendations, and the Government may rely on material gathered before, during, and after the objections stage. The proceeding is therefore not a lis between two contesting parties requiring adjudication by an outside authority; it is a step in the executive process by which the Government forms its subjective satisfaction. The provision in the rules for limited rebuttal and cross-examination does not convert the proceeding into a judicial one.
Conclusion: The inquiry under section 5A is an administrative inquiry, not a quasi-judicial inquiry, and the Government is not bound to act judicially while deciding the objections.
Final Conclusion: The challenge to the inquiry failed, and the petition was dismissed with costs.
Ratio Decidendi: Where the statute makes the Government's subjective satisfaction the basis of acquisition and uses a preliminary objection process only to inform that satisfaction, the objection inquiry remains administrative unless the statute clearly imposes a duty to act judicially.