Mahanadi Coal Fields Ltd. & Anr. Vs. Mathias Oram & Ors. [Miscellaneous Application No. 2662/2023]
- ByPravleen Kaur --
- 15 Jun 2025 --
- 0 Comments
The Supreme Court of India, in Mahanadi Coal Fields Ltd. & Anr. vs. Mathias Oram & Ors. [Miscellaneous Application No. 2662/2023], delivered its order on January 3, 2025, addressing ongoing issues related to land acquisition, compensation, and rehabilitation and resettlement benefits for villages acquired by Mahanadi Coal Fields Ltd. (MCL) under the Coal Bearing Areas (Acquisition and Development) Act, 1957, and the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013.
Facts and Background
MCL acquired vast tracts of land in Odisha, including villages such as Gopalpur, Sardega, Balinga, and others, for coal mining operations. The acquisition dates back to 1987, and the ownership of the land vested with MCL. However, physical possession of large portions, excluding mining areas, was not taken. To address compensation and rehabilitation claims of land oustees, the Supreme Court appointed a Claims Commission to determine fair compensation and rehabilitation benefits.
The Claims Commission submitted reports for several villages based on a model known as the “Gopalpur Model,” which was approved by the Court and made final orders. However, disputes continued regarding compensation for other villages and the extension of the Claims Commission’s term. Several applications were filed by MCL and landowners seeking directions on various issues.
Legal Issues
Determination and finality of compensation and rehabilitation benefits for land oustees in acquired villages.
The scope of the Claims Commission’s authority and the extension of its term.
Whether re-determination of compensation is permissible after the Court’s approval of the Claims Commission’s reports.
Jurisdiction over fresh disputes relating to calculation and disbursement of compensation and benefits.
Supreme Court’s Findings and Directions
The Court reiterated its earlier ruling dated November 3, 2022, that the “Gopalpur Model” applied to ten villages whose compensation reports were approved and finalized by the Court, precluding any re-determination of compensation for those villages. The Court emphasized that the issues concerning these villages stood conclusively settled.
Regarding four other villages—Tumulia, Jhupuranga, Ratansara, and Kirpsara—no awards had been approved as of that date, and proceedings were ongoing.
The Court directed that any fresh disputes concerning compensation calculation, disbursement of benefits, or related matters must be adjudicated by the High Court and that the Supreme Court would not entertain miscellaneous applications on individual grievances in this regard.
The Court also permitted MCL to appoint a new representative in place of a former director to handle ongoing proceedings.
Conclusion
This order affirms that:
Compensation and rehabilitation benefits determined and approved by the Claims Commission and the Supreme Court are final and binding for the approved villages.
Reopening or re-determination of settled compensation is not permissible.
Fresh disputes or grievances must be resolved by the appropriate High Court jurisdiction.
The Claims Commission’s role and term are subject to the Court’s directions to ensure orderly resolution of pending claims.
This ruling provides clarity and finality to long-standing land acquisition disputes involving MCL, balancing the rights of land oustees with the operational needs of the coal mining enterprise, while directing procedural discipline in resolving residual claims.
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