The Supreme Court held that the restoration remedy in Kedar Nath Yadav, grounded in protecting vulnerable agricultural communities, does not extend to industrial entities. A party that accepted compensation without challenge and failed to pursue statutory remedies cannot belatedly claim relief from a judgment secured by others through public interest litigation.
Facts Of The Case:
The case concerns a dispute over the restoration of 28 Bighas of land in Singur, West Bengal, originally acquired in 2006 for the Tata Nano manufacturing project. The land was purchased and converted for industrial use by M/s Santi Ceramics Pvt. Ltd. (Respondent No. 1), which established a manufacturing unit thereon. The acquisition process, conducted under the Land Acquisition Act, 1894, was subsequently quashed by the Supreme Court in 2016 in Kedar Nath Yadav v. State of West Bengal on grounds of procedural violations, and restoration was ordered for original landowners/cultivators.Following this judgment, Santi Ceramics, which had previously accepted over ₹14 crore in compensation without protest, sought restoration of its land and structures, claiming parity with the cultivators. The Calcutta High Court allowed the claim. The State of West Bengal appealed to the Supreme Court, arguing that the Kedar Nath Yadav remedy was specifically tailored for disadvantaged agricultural communities and not for a financially capable industrial entity that had acquiesced to the acquisition for a decade.
Procedural History:
The procedural history begins with the 2006 acquisition of the land under the Land Acquisition Act, 1894, for the Tata Nano project. Santi Ceramics filed objections under Section 5-A, which were rejected, and it subsequently accepted the compensation award without further challenge. The acquisition’s validity was contested by affected farmers through a Public Interest Litigation (PIL), ultimately leading to the Supreme Court’s 2016 judgment in Kedar Nath Yadav quashing the proceedings. In 2016, Santi Ceramics then filed Writ Petition No. 29621/2016 before the Calcutta High Court seeking restoration, which was allowed by a Single Judge in April 2017. A Division Bench of the High Court upheld this decision in its Impugned Judgment dated October 11, 2018. The State’s appeal to the Supreme Court resulted in the instant 2025 judgment, which reversed the High Court’s orders.
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Court Observation:
The Supreme Court observed that the restoration remedy crafted in Kedar Nath Yadav was a targeted judicial intervention designed specifically to protect vulnerable agricultural communities facing destitution due to procedural violations and their lack of resources to challenge state action. It held that this protective framework did not extend to a financially resourced industrial entity like Santi Ceramics. The Court further noted that a party which voluntarily accepts full compensation without demur, fails to exhaust statutory remedies, and remains passive for a decade while others litigate, cannot belatedly claim the benefit of a judgment secured through a Public Interest Litigation. Such a claim would undermine the finality of acquisition proceedings and incentivize strategic inaction.
Final Decision & Judgement:
The Supreme Court allowed the State’s appeal and set aside the judgments of the Calcutta High Court. It held that Respondent No. 1, M/s Santi Ceramics, was not entitled to the restoration remedy established in Kedar Nath Yadav and dismissed its writ petition challenging the acquisition. However, the Court issued consequential directions permitting the company to remove its remaining structures from the land within three months or have them auctioned, with proceeds returned after deducting expenses. The Appellants were directed to resume possession of the subject land after fresh demarcation.
Case Title: The State of West Bengal and Others vs. M/S Santi Ceramics Pvt. Limited and Another Civil Appeal No. (Arising out of SLP (C) No(s). 33701/2018). Date of Judgment: October 13 2025 Judges/Justice Name: Justice Surya Kant and Justice Joymaiya Bagchi
Download The Judgement Here