Bhuneshwari Devi and Others v. Union of India and Others, 2026

The case arose from a long-pending land acquisition compensation dispute relating to land acquired for the Rajrappa Project of Central Coalfields Limited (CCL).

The appellants were claimants seeking compensation for land acquired in connection with the project.

The Land Acquisition Tribunal had rejected their claim, principally because the original claimant had not produced the relevant Form-K/Purcha document before the Tribunal.

The appellants contended that this approach was erroneous because other claimants relating to the same Khata number and Plot number had already received compensation.

According to the appellants, the same Purcha/document had been produced and considered in those connected claim proceedings.

The document had reportedly been marked as Ext.8/d in Claim Case Nos. 94 and 95 of 1993 and had formed part of the basis for granting compensation to similarly situated raiyats.

The appellants therefore sought permission to place the relevant document and other material before the appellate court as additional evidence.

For this purpose, they filed an application under Order XLI Rule 27 CPC.

The High Court examined the Tribunal's reasoning and found that the claim had been rejected essentially because the relevant document had not been produced before the Tribunal.

The Court noted that the same document had already been relied upon in other claim proceedings concerning the same Khata and Plot numbers.

The Court consequently considered it necessary to permit the additional material to be brought on record so that the compensation claim could be properly adjudicated.

The Jharkhand High Court allowed the application under Order XLI Rule 27 CPC and permitted the appellants to place the additional documents on record.

The Court found that the document in question was relevant to the determination of the compensation claim.

The Court noted that the same document had already been considered in other claim proceedings concerning the same Khata number and Plot number.

Therefore, the document could not simply be disregarded in the appellants' case when it had been relied upon for determining compensation payable to similarly situated claimants.

The Court held that an application under Order XLI Rule 27 CPC can be allowed during the hearing when the relevance and statutory requirements for admitting additional evidence are established.

The Tribunal had rejected the claim primarily because Ext.8/d had not been produced before it.

Since the appellate court found the document relevant and found that it had been considered in connected proceedings, it permitted the appellants to bring it on record.

The High Court consequently set aside the Land Acquisition Tribunal's judgment dated 29 September 2018.

The compensation claim was restored to the Tribunal's original file for fresh consideration.

The Tribunal was directed to reconsider the matter after taking into account the additional documents permitted to be produced before the High Court.

The Tribunal was further directed to decide the compensation dispute afresh in accordance with law.

Relevance of additional evidence: The decision reinforces that Order XLI Rule 27 CPC is designed to prevent relevant evidence from being excluded merely because it was not produced at the earlier stage, provided the statutory requirements for admitting additional evidence are fulfilled.

Consistency in compensation adjudication: The Court gave importance to the fact that the same document had already been considered in proceedings involving the same land records. This reduces the possibility of inconsistent outcomes for similarly situated landowners.

Importance of land records: In land acquisition disputes, documents such as Form-K/Purcha and other revenue records can be crucial for establishing title, possession, entitlement and the basis for compensation.

Limited scope of appellate intervention: The High Court did not itself determine the final amount of compensation. Instead, it restored the matter to the Tribunal so that the relevant evidence could be examined in the first instance.

Natural justice and proper adjudication: Allowing relevant documentary evidence to be considered helps ensure that the final determination is based on the material necessary to resolve the actual dispute.

Same evidence, similarly placed claimants: The case highlights an important practical principle: where a particular document has already been accepted and relied upon in connected compensation claims concerning the same land records, its relevance to another claim involving the same land cannot be disregarded without proper consideration.

Effect of remand: The High Court did not finally hold that the appellants were unquestionably entitled to a particular amount of compensation. It directed the Tribunal to reconsider the claim afresh after taking the additional material into account.

Procedural significance: The judgment demonstrates that procedural rules such as Order XLI Rule 27 CPC can play an important role in ensuring that potentially decisive evidence is available to the adjudicating forum.