Ranveer Singh v. State of U.P. Through Secy. & Ors.
Background
The appellant's agricultural land in Gautam Budh Nagar, U.P. was acquired in 2000-2001, and possession was taken in February 2001. Because of a dispute over whether the appellant held land in excess of the permissible ceiling, compensation was only finalised and paid in February 2003 through a negotiated agreement, which the appellant accepted without protest. He later sought additional statutory interest under Section 34 of the Act for the gap between taking of possession and payment, but this claim was rejected by the District Magistrate and, on a fresh writ petition, by the Allahabad High Court.
Decision Breakdown
The Supreme Court held that once a landowner enters into a consent agreement for compensation under Section 11(2) of the Act and accepts the agreed amount without protest, especially where the agreement itself states he will not claim any additional amount, that consent award is treated as full and final compensation, deemed to already include any interest component up to the date of agreement. Relying on its earlier rulings in Daya Shamji Bhai and Sangappa Dyavappa Biradar, the Court held that accepting a consent award without protest extinguishes both the remedy of seeking a reference for enhancement and the underlying right to claim more, including statutory interest. The Court also rejected an equity-based argument, noting the appellant had in fact received a much higher negotiated rate than other landowners who did not enter into such an agreement. Finding no error in the High Court's view, the appeal was dismissed, though without costs.
Lesson Learnt
If you sign a compensation agreement and accept payment "without protest" and with an explicit promise not to claim anything further, courts will generally hold you to that bargain: you give up the right to later come back and demand extra statutory interest or enhancement, even if the law would otherwise have entitled you to it.