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Issues Involved:
1. Whether a company for whose benefit land is acquired under the Land Acquisition Act, 1894, can be impleaded as a party in the Court of the District Judge in a reference under Section 18 of the Act. Detailed Analysis: Issue 1: Whether a company for whose benefit land is acquired under the Land Acquisition Act, 1894, can be impleaded as a party in the Court of the District Judge in a reference under Section 18 of the Act. Background and Contentions: The State of Haryana initiated acquisition proceedings under Sections 4 and 6 of the Land Acquisition Act for setting up a wristwatch manufacturing factory by the petitioner-company, M/s. Indo Swiss Time Ltd. The landowners sought enhancement of compensation, leading to a reference under Section 18 of the Act to the District Judge, Gurgaon. The petitioner-company sought to be impleaded as a respondent under Section 50(2) of the Act read with Order 1, Rule 10 of the Civil Procedure Code (CPC). The Additional District Judge allowed the company to appear and adduce evidence but denied its request to be impleaded as a party. Aggrieved, the petitioner-company filed civil revisions. Legal Principles and Precedents: The petitioner-company argued that it is "directly and vitally interested" in the compensation and thus qualifies as a "person interested" under Section 3(b) of the Act. The company cited the Supreme Court's decision in Himalaya Tiles and Marble (P) Ltd. v. Francis Victor Coutinho, AIR 1980 SC 1118, which held that a company for whose benefit land is acquired is a "person interested" and can maintain an appeal against an adverse order. The respondents contended that the company's only right is to adduce evidence for determining compensation and that it is not a "person interested" entitled to be impleaded as a party. They relied on the Supreme Court's decision in Municipal Corporation of the City of Ahmedabad v. Chandulal Shamaldas Patel, (1970) 1 SCWR 183, which held that a company has no interest to file an appeal in acquisition proceedings. Judgment: The majority judgment (Sandhawalia, C.J. and P. Jain, J.) held that a company for whose benefit land is acquired can be impleaded as a party in a reference under Section 18 of the Act. They relied on the Supreme Court's decision in Himalaya Tiles, emphasizing that the definition of "person interested" must be liberally construed. The Court held that the company's interest in the compensation and its right to appeal necessitate its impleading as a party under Order 1, Rule 10 of the CPC, harmonized with Section 50(2) of the Act. The dissenting judgment (Tandon, J.) preferred the view in Municipal Corporation of Ahmedabad, holding that a company is not a "person interested" and cannot be impleaded as a party. The dissent emphasized that the company's right is limited to adducing evidence for compensation determination and does not extend to being a party or filing an appeal. Conclusion: The majority judgment concluded that a company for whose benefit land is acquired can be impleaded as a party in the Court of the District Judge in a reference under Section 18 of the Land Acquisition Act, 1894. This impleading is within the confines of Section 50(2) of the Act. Consequently, the civil revisions were allowed, modifying the Additional District Judge's order to permit the petitioner-company to be impleaded as a party. The dissenting opinion, however, held that the company's application under Order 1, Rule 10 of the CPC is not maintainable, and it cannot be considered a "person interested" entitled to be a party in the proceedings. The revision petitions were dismissed by the dissenting judge.
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