Conflicting Supreme Court precedents and land acquisition impleadment in restricted Section 18 references

Where two co-equal Supreme Court decisions conflict, a High Court should follow the ruling that more accurately and elaborately states the law, rather than treating the later decision as automatically binding. In land acquisition references under Section 18, the jurisdiction is special and limited: although "person interested" is construed broadly, the reference remains confined to persons before the Collector and to issues arising from that reference. A stranger to the acquisition proceedings cannot be impleaded under Order I Rule 10 to convert the matter into a wider title dispute. The revision petition therefore failed and the impleadment applications were rejected.

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Issues: (i) When two decisions of the Supreme Court delivered by co-equal Benches are in direct conflict, which decision should a High Court follow? (ii) Whether a person who was not before the Land Acquisition Officer can maintain an application for impleadment under Order I, Rule 10 of the Civil Procedure Code in reference proceedings under Section 18 of the Land Acquisition Act?

Issue (i): Where two co-equal decisions of the Supreme Court cannot be reconciled, the binding force of precedent does not turn merely on the date of decision. The proper course is to adopt the ruling that states the law more accurately and more elaborately, having regard to the reasoning, logic, and correctness of the view. A later judgment does not automatically prevail simply because it is later in time.

Conclusion: The High Court must follow the Supreme Court decision which appears to lay down the law more elaborately and accurately.

Issue (ii): The expression "person interested" in the Land Acquisition Act is to be construed broadly, but the reference jurisdiction under Section 18 is a special and limited jurisdiction. The scheme of Sections 18 to 21, read with the limitation built into Section 18(2), shows that the reference before the District Judge is confined to persons who were before the Collector and to the matters arising from that reference. Permitting strangers to the acquisition proceedings to be impleaded would enlarge the enquiry into a general title dispute and defeat the statutory scheme.

Conclusion: A person who was not before the Land Acquisition Officer cannot successfully be impleaded as a party under Order I, Rule 10 in proceedings under Section 18 of the Land Acquisition Act.

Final Conclusion: The revision petition fails because the applications for impleadment were rightly rejected in the restricted reference jurisdiction under the Land Acquisition Act.

Ratio Decidendi: In case of irreconcilable conflict between co-equal Supreme Court decisions, the High Court should follow the one that states the law more accurately; and in a Section 18 land acquisition reference, the court cannot enlarge the proceeding by impleading persons who were not before the Collector.

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