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Issues Involved:
1. Conflict between two decisions of the Supreme Court by co-equal Benches. 2. Maintenance of an application for being impleaded as a party under Order I, Rule 10 of the Civil Procedure Code (CPC) in reference proceedings before the District Judge under Section 18 of the Land Acquisition Act. Issue-wise Detailed Analysis: 1. Conflict between two decisions of the Supreme Court by co-equal Benches: The judgment addresses the situation where there is a direct conflict between two decisions of the Supreme Court rendered by co-equal Benches. It was argued that the earlier judgment should be followed if the latter one missed consideration of the former. However, the court concluded that the High Court must follow the judgment that appears to state the law more elaborately and accurately, irrespective of the time of its delivery. The court emphasized that the weight of the judgment should be considered by its rational and logic rather than the date it was rendered. The court cited various precedents and legal authorities to support this view, including the observations of Jessel M. R. in Hampton v. Holman and the Full Bench judgment in Indo Swiss Time Limited v. Umrao. 2. Maintenance of an application for being impleaded as a party under Order I, Rule 10 of the CPC in reference proceedings before the District Judge under Section 18 of the Land Acquisition Act: The court examined whether a person who was not before the Land Acquisition Officer can maintain an application to be impleaded as a party in the reference proceedings before the District Judge under Section 18 of the Land Acquisition Act. The court concluded that the concept of 'person interested' in the Land Acquisition Act has to be construed widely. However, the mere fact that a person was not before the Land Acquisition Officer does not conclusively bar them from being a 'person interested'. The court referred to various statutory provisions and precedents, including the Supreme Court's decision in Himalaya Tiles and Marble (Private) Ltd. v. Francis Victor Coutinho, which emphasized a liberal construction of the term 'person interested'. Despite this, the court held that even if a person is considered a 'person interested', they cannot be impleaded as a party in the reference proceedings if they were not before the Land Acquisition Officer. The court emphasized that the jurisdiction of the District Judge in reference proceedings is special and limited, confined to the matters specifically referred by the Collector. The court referred to Sections 18, 19, and 21 of the Land Acquisition Act, which indicate that the parties before the court are those who were before the Collector. The court also highlighted the need to prevent the conversion of reference proceedings into complicated title suits involving intricate disputes. The court concluded that a person who was not before the Land Acquisition Officer cannot successfully maintain an application for being impleaded as a party under Order I, Rule 10 of the CPC in the reference proceedings before the District Judge under Section 18 of the Land Acquisition Act. The court affirmed the decision of the lower court in rejecting the application under Order I, Rule 10 of the CPC. Separate Judgments: All three judges (S.S. Sandhawalia, C.J., Nagendra Prasad Singh, and M.P. Varma, JJ.) agreed with the conclusions and reasoning provided in the judgment.
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