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- Compliance with the rules of natural justice in the enquiry under Rule 4 of the Land Acquisition (Companies) Rules, 1963. Detailed Analysis: The judgment involves three appeals challenging a High Court decision related to land acquisition proceedings under the Land Acquisition Act, 1894. The appeals questioned the compliance with the rules of natural justice in the enquiry under Rule 4 of the Land Acquisition (Companies) Rules, 1963. The appeals arose from notifications issued under Sections 4 and 6 of the Act for the acquisition of lands for establishing an industrial estate. The High Court allowed the petitions filed by the landowners, setting aside the Section 6 notification and mandating completion of the statutory enquiry under Rule 4 with adherence to natural justice principles. The central question before the Supreme Court was whether the enquiry under Rule 4 of the Rules necessitates adherence to the principles of natural justice. The Court referred to previous judgments emphasizing that rules of natural justice may be implied based on the duty to be performed under a statute. The Court analyzed the provisions of Rule 4, which outline the requirements for the appropriate Government and the Collector in land acquisition proceedings. Rule 4 mandates the appropriate Government to direct the Collector to report on specific matters when a Company applies for land acquisition. The Collector is required to conduct an enquiry into these matters, including consultation with the Senior Agricultural Officer in case of agricultural land, determination of compensation, and ascertaining the Company's offer to interested persons. The rule underscores the importance of the enquiry for the affected parties. The Court concluded that the Collector's enquiry, crucial for assessing the Company's efforts and compensation, must adhere to natural justice principles. Despite the rule's silence on the method of enquiry, the Court held that fairness demands affording affected parties a reasonable opportunity to be heard and present evidence. The Court highlighted the evolving concept of natural justice and the blurred line between administrative and quasi-judicial functions. The Court cited a previous judgment to support its stance, emphasizing that landowners have the right to be heard during the enquiry under Rule 4 to establish the Company's negotiation efforts. The Court rejected the State's argument that owners could be heard during a later enquiry under Section 5-A, stating that such an enquiry may not occur. Ultimately, the Court answered the question in the affirmative, affirming the importance of natural justice in the enquiry process and dismissing the appeals while leaving the parties to bear their own costs.
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