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October 2026

Manav Bhanot v. National Highway Authority of India: Compensation benefits for highway land acquisitions determined before 01.01.2015 are computed under Land Acquisition Act, 1894.

By Dr. K. Shivaram, Senior Advocate, Rahul K. Hakani | Shashi Bekal, Advocates
Reading Time 2 mins

33. Manav Bhanot v. National Highway Authority of India

2026 INSC 973 September 8, 2026

Land acquisition – National Highways Act – solatium and interest – applicability of 1894 Act or 2013 Act – compensation determined before 1.1.2015 – benefits to be computed under 1894 Act.

[National Highways Act, 1956, Ss.3G, 3H; Land Acquisition Act, 1894; Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013, Ss.24, 105]

FACTS

The appellant’s land was acquired under the National Highways Act. The notification under section 3A was issued in 2011, and the declaration under section 3D was made in 2012.

The Competent Authority determined compensation on 11.07.2014. The appellant received part of the compensation but disputed the quantum, resulting in an arbitration proceeding. The dispute before the Supreme Court concerned the statute under which solatium, interest and interest on solatium were required to be computed.

The appellant contended that the beneficial provisions of the 2013 Act should apply. NHAI contended that the 2013 Act became applicable to acq

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