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Eastern Coalfields Limited v. Anadinath Banerjee (D) & Ors.

Civil Appeal · 2021 INSC 351Decided 23 Jul 2021
Civil Appeal Nos. 2887-2889 of 2021
Dr. Justice D.Y. Chandrachud · Justice M.R. Shah

Background

Under a rehabilitation scheme, persons who lost at least 2 acres of land to Eastern Coalfields' mining expansion were entitled to employment. The respondent's own landholding, as per the Land Acquisition Collector's certificate, was only 0.3 acres; he reached the 2.01-acre threshold only by adding land belonging to relatives (father, brother, nephews) who had executed affidavits in his favour. The High Court (Single Judge and Division Bench) had accepted this combined figure and directed Eastern Coalfields to give him employment.

Decision Breakdown

The Supreme Court held that self-serving affidavits from relatives do not transfer any title or legal interest in land, and so cannot be added to a claimant's own landholding to meet an eligibility threshold meant to measure the specific individual's/family's loss. Examining how "family" is treated as the relevant unit under compensation and rehabilitation law (including the 2013 Land Acquisition Act's definition), the Court held that affidavit-donors who were not dependents of the respondent could not be clubbed with him as one family unit. Since the respondent's own documented landholding fell short of the 2-acre threshold, the Court set aside the High Court's judgments and dismissed the respondent's original writ petition.

Lesson Learnt

Eligibility thresholds based on landholding size must be proven through actual title documents and cannot be inflated by informal affidavits from relatives who have no dependent relationship with the claimant; courts look to genuine legal title and family-unit rules, not paper arrangements, when deciding entitlement under rehabilitation schemes.

Official source (sci.gov.in)View Judgment (PDF)

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