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Sanjay Kumar Singh vs. The State of Jharkhand

Civil Appeal · 2022 INSC 293Decided 10 Mar 2022
Civil Appeal No. 1760 of 2022

Background

The appellant's land was acquired in 1980 under the Land Acquisition Act, 1894, and he was awarded compensation of only Rs. 92,121. His request for enhanced compensation was rejected by the Reference Court, and only one sale deed (which was disallowed) was on record to prove the land's fair market value. When he appealed to the Jharkhand High Court, he tried to bring on record additional sale deeds and related judgments to help establish a fair market value, but the High Court refused to allow this additional evidence and dismissed his appeal.

Decision Breakdown

The Supreme Court held that the High Court had failed to apply the correct legal test for admitting additional evidence under Order 41 Rule 27 of the Civil Procedure Code: the real question is whether the appellate court needs the additional evidence to pronounce judgment properly, not merely whether the party could have produced it earlier. Since the only other evidence on record had already been rejected, leaving no material to assess fair compensation, the Court held the High Court should have allowed the additional documents in the interest of justice. It set aside the High Court's order, allowed the additional evidence to be brought on record, and sent the matter back to the Reference Court, directing that the appellant must still formally prove the authenticity and genuineness of these documents before they can be relied upon.

Lesson Learnt

Courts can allow new evidence at the appeal stage in exceptional situations, especially where without it the court simply cannot arrive at a fair and just decision (such as fixing fair compensation for acquired land), but permission to file such evidence is not the same as it being accepted as true; it still must be proved.

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

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