Natural justice applies to Rule 4 land acquisition enquiries, requiring a reasonable hearing for interested persons.

Rule 4 of the Land Acquisition (Companies) Rules, 1963 requires the Collector to examine matters directly affecting the legality and propriety of acquisition for a company, including negotiation efforts, suitability of the land, excess area, expeditious utilisation, and availability of an alternative site for agricultural land. Because the report forms a material basis for the Government's satisfaction before a Section 6 declaration is made, the enquiry is not a mere internal formality. Even without an express hearing provision, the nature and consequences of the process require observance of natural justice. Persons interested in the land are therefore entitled to a reasonable opportunity of being heard, and the appeals were dismissed.

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Issues: Whether the enquiry contemplated by Rule 4 of the Land Acquisition (Companies) Rules, 1963 requires observance of the principles of natural justice by affording the persons interested in the land a reasonable opportunity of being heard.

Analysis: Rule 4 requires the Collector to investigate matters going directly to the legality and propriety of acquisition for a company, including whether reasonable efforts at negotiation were made, whether the land is suitable, whether the area is excessive, whether the company can utilise the land expeditiously, and, in the case of agricultural land, whether an alternative suitable site exists. The report under the rule is material to the Government's satisfaction before a declaration under Section 6 of the Land Acquisition Act, 1894 is made. Although the rule does not expressly prescribe the manner of enquiry and the Collector's report is recommendatory, the nature and object of the enquiry, and the consequences for persons interested in the land, make fair hearing essential. The absence of an express hearing provision does not exclude natural justice where the statute and the rules indicate that affected persons' interests are directly involved. The enquiry is therefore not a mere internal administrative formality.

Conclusion: The enquiry under Rule 4 does require observance of the principles of natural justice, and the persons interested in the land are entitled to a reasonable opportunity of being heard. The appeals fail and stand dismissed.

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