Supreme Court of India
UNION OF INDIA & ANR.versusTARSEM SINGH & ORS.
- Citation
- 2025 INSC 146
- Decided
- 3 February 2025
- Disposal
- Dismissed
- Bench
- SURYA KANT
Holding
The Tarsem Singh judgment must be applied retrospectively to all affected land acquisitions, as prospective application would defeat its purpose and violate Article 14.
Summary
The National Highways Authority of India (NHAI) filed a miscellaneous application seeking clarification on whether the Supreme Court's 2019 judgment in Union of India v. Tarsem Singh, which mandated payment of solatium and interest to landowners whose land was acquired under the NHAI Act, should operate only prospectively, thereby preserving the finality of earlier acquisitions. The issue before the Court was whether the Tarsem Singh judgment should be applied prospectively or retrospectively to acquisitions made between 1997 and 2015. The Court held that a prospective limitation would nullify the purpose of the earlier judgment, which was to rectify the unequal treatment created by Section 3J of the National Highways Act and to uphold Article 14. It reasoned that granting solatium and interest does not reopen settled cases but merely provides additional statutory benefits, and that a prospective rule would create an unjust classification of similarly situated landowners. Consequently, the Court dismissed the miscellaneous application, affirming that the Tarsem Singh decision applies retrospectively and directing the competent authority to calculate the owed solatium and interest.
Issues considered
- Whether the Supreme Court judgment in Union of India v. Tarsem Singh should be applied prospectively or retrospectively to land acquisitions under the National Highways Act between 1997 and 2015.
- Whether granting solatium and interest under the Tarsem Singh judgment amounts to reopening concluded cases, thereby violating the doctrine of immutability.
Legislation cited
Subjects
Land AcquisitionSolatiumInterestIntelligible differentiaArticle 14 of ConstitutionSection 3J of National Highways Act, 1956Determination of compensationProspectivelyRetrospectively
Judgment
[2025] 2 S.C.R. 376 : 2025 INSC 146
Union of India & Anr.
v.
Tarsem Singh & Ors.
(Miscellaneous Application No. 1773 of 2021
In
Civil Appeal No. 7064 of 2019)
04 February 2025
[Surya Kant* and Ujjal Bhuyan, JJ.]
Issue for Consideration
Whether the judgment in Union of India v. Tarsem Singh & Ors. is
applicable prospectively or extends retrospectively.
Headnotes†
Land Acquisition Act, 1894 – National Highways Act, 1956 –
Right to Fair Compensation and Transparency in Land
Acquisition, Rehabilitation and Resettlement Act, 2013 – The
National Highways Authority of India (NHAI) seeks clarification
regarding the judgment titled Union of India & Anr. v. Tarsem
Singh & Ors to the extent that the aforementioned judgment is
to be applied prospectively, thereby precluding the reopening
of cases where land acquisition proceedings have already
been completed and the determination of compensation had
also attained finality:
Held: The prayer in the instant Application expressly seeks
clarification that the decision in Tarsem Singh should be deemed
to operate prospectively only – However, in considered view of
this Court, granting such a clarification would effectively nullify
the very relief that Tarsem Singh intended to provide, as the
prospective operation of it would restore the state of affairs to
the same position as it was before the decision was rendered –
The broader purpose behind Tarsem Singh was to resolve and
put quietus upon the quagmire created by s.3J of the NHAI Act,
which led to the unequal treatment of similarly situated individuals
– The impact of s.3J was short-lived, owing to the applicability of
the 2013 Act upon the NHAI Act from the date of 01.01.2015 –
* Author
[2025] 2 S.C.R. 377
Union of India & Ors. v. Tarsem Singh & Ors.
As a result, two classes of landowners emerged, devoid of any
intelligible differentia: those whose lands were acquired by the
NHAI between 1997 and 2015, and those whose lands were
acquired otherwise – This must be viewed in the light of the
principle that when a provision is declared unconstitutional, any
continued disparity strikes at the core of Article 14 and must be
rectified, particularly when such disparity affects only a select
group – To illustrate, rendering the decision in Tarsem Singh as
prospective would create a situation where a landowner whose
land was acquired on 31.12.2014 would be denied the benefit of
‘solatium’ and ‘interest’, whereas a landowner whose land was
acquired the very next day, 01.01.2015-the date on which the
ordinance was promulgated, to read the 2013 Act into the NHAI
Act, would be entitled to these statutory benefits – No merit in
the contentions raised by the applicant – Principles established in
Tarsem Singh regarding the beneficial nature of granting ‘solatium’
and ‘interest’ while emphasising the need to avoid creating unjust
classifications lacking intelligible differentia are reaffirmed –
Consequently, the present Miscellaneous Application is dismissed.
[Paras 17, 18, 19, 25]
Case Law Cited
Union of India v. Tarsem Singh [2019] 13 SCR 49 : (2019) 9 SCC
304; National Highway Authority of India v. Resham Singh, 2023 :
PHHC : 053158-DB; Lalita v. Union of India, 2002 SCC Online
Kar 569; T. Chakrapani v. Union of India, 2011 SCC Online
Mad 2881; Sunita Mehra v. Union of India (2019) 17 SCC 672;
Union of India v. M. Pachamuthu, WA Nos. 62-81/2019; Gurpreet
Singh v. Union of India [2006] Supp. 7 SCR 422 : (2006) 8 SCC
457 – referred to.
List of Acts
Land Acquisition Act, 1894; National Highways Act, 1956; Right
to Fair Compensation and Transparency in Land Acquisition,
Rehabilitation and Resettlement Act, 2013; Constitution of India.
List of Keywords
Land Acquisition; Solatium; Interest; Intelligible differentia; Article 14
of Constitution; Section 3J of National Highways Act, 1956;
Determination of compensation; Prospectively; Retrospectively.
378 [2025] 2 S.C.R.
Digital Supreme Court Reports
Case Arising From
CIVIL APPELLATE JURISDICTION: Miscellaneous Application
No. 1773 of 2021
In
Civil Appeal No. 7064 of 2019
From the Judgment and Order dated 19.09.2019 of the Supreme
Court of India in C.A. No. 7064 of 2019
With
Civil Appeal Nos. 1473-1541, 1542, 1543, 1544, 1545, 1546,
1547-1553, 1554, 1555, 1556-1561 And 1562 of 2025
Appearances for Parties
Tushar Mehta, Solicitor General, Ms. Kalyani Bhide, Kalyani Bhide,
Anurag A Gharote, Anish Kathane, Mrs. Pragya Baghel, Maulik
Nanavati, Ms. Jaikriti S. Jadeja, Pratyush Shrivastav, Ms. Manvi
Damle, Shivang Goel, Ishaan Aggarwal, Arvind Gupta, Satyajit A
Desai, Harnish Ghadiya, Siddharth Gautam, Abhinav K. Mutyalwar,
Sachin Singh, Ananya Thapliyal, Ms. Anagha S. Desai, Preetraj
Dhok, M/S. M. V. Kini & Associates, K. K. Mani, Ms. T. Archana,
Rajeev Gupta, Sumit Gupta, Akshay Tiwari, Venkita Subramoniam
T.R, Advs. for the Appellant.
Tushar Mehta, Solicitor General, V Krishnamurthy, Sr. A.A.G., C U
Singh, Sr. Adv., P Sivakumar, Y Arunagiri, Raghunatha Sethupathy
B (for P. Soma Sundaram), Satyajit A Desai, Harnish Gadhia,
Harnish Ghadiya, Siddharth Gautam, Abhinav K. Mutyalwar, Ms.
Anagha S. Desai, Maulik Nanavati, Ms. Jaikriti S. Jadeja, Pratyush
Srivastava, Ms. Manvi Damle, Shivang Goel, Ishaan Aggarwal, Ms.
Jay Jaimini Pandey, Satish Pandey, Ms. Lalita Gupta, Abhishek
Kumar Singh, Anirudh Bankura, Ms. Vijay Lakshmi, Braj Kishora
Mishre, Pradeep Kumar Arya, Prateek Singh, Rupesh Goel, Aditya
Yadav, Gaurav Chaudhry, Ms. Garima Chaudhry, Chander Shekhar
Ashri, Arvind Gupta, D.Kumanan, Ms. Deepa S, Sheikh F Kalia,
Veshal Tyagi, Chinmay Anand Panigrahi, Ms. Azka Sheikh Kalia,
Mrs. Kalyani Bhide, Gharote Anurag A, Anish Kathane, Nitin Lonkar,
Siddharth Dharmadhikari, Aaditya Aniruddha Pande, Siddharth
Mittal, Abhijeet Varshney, Deepak Agarwal, Darshan Sejwal, Sumit
Kumar Sharma, Mrs. Shilpa G Mittal, Somiran Sharma, Raghuvir
Singh Patil, S C Malhotra, Kunal Kishore, Sudhansu Palo, Vivak
Verma, Vijay Mittal, Mayank Kshirsagar, Advs. for the Respondent.
S.C. Malhotra, Bishen Singh, Ms. Sadhna, Advs. for the Intervenor.
[2025] 2 S.C.R. 379
Union of India & Ors. v. Tarsem Singh & Ors.
Judgment / Order of the Supreme Court
Order
Surya Kant, J.
1. The instant Miscellaneous Application, filed by the National Highways
Authority of India (NHAI) through its Project Director, seeks clarification
regarding the judgment dated 19.09.2019, passed in Civil Appeal
No. 7064 of 2019, titled Union of India & Anr. v. Tarsem Singh &
Ors,1 to the extent that the aforementioned judgment is to be applied
prospectively, thereby precluding the reopening of cases where
land acquisition proceedings have already been completed and the
determination of compensation had also attained finality.
2. This Miscellaneous Application is tagged with several appeals filed
by the NHAI challenging the decisions of various High Courts at the
instance of private parties, wherein relief has been granted relying on
the judgment dated 19.09.2019. The High Courts vide these decisions
have either (i) awarded ‘solatium’ and ‘interest’ to the expropriated
landowners; or (ii) directed the Competent Authority (Land Acquisition,
National Highways) to consider and decide representations made by
the landowners for the grant of ‘solatium’ and ‘interest’ in light of the
aforementioned judgment of this Court. This also includes SLP (C)
No. 14942/2019 titled ‘K. Raju and others v. The Project Director,
National Highways Authority of India and others’, which has been
preferred by a private party assailing the decision of the Madras
High Court dated 01.04.2019, whereby the relief of ‘solatium’ and
‘interest’ was directed to be raised before the Competent Authority.
3. Additionally, SLP (C) Diary No. 52538/2023 titled ‘Raj Kumar and
another v. Union of India and others’, has been preferred by a
private party whose lands were acquired by NHAI. In this instance,
the Punjab and Haryana High Court has rejected their claim for
the award of ‘Additional Market Value’ relying upon its decision in
National Highway Authority of India v. Resham Singh,2 whereby
the landowners were held entitled to ‘solatium’ and ‘interest’, but their
1 Union of India v. Tarsem Singh, (2019) 9 SCC 304.
2 National Highway Authority of India v. Resham Singh, 2023:PHHC:053158-DB.
380 [2025] 2 S.C.R.
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claim for the grant of ‘Additional Market Value’ was declined. These
benefits were granted / partly declined in terms of Sections 23(2) and
28 of the Land Acquisition Act, 1894 (1894 Act), which were read
into the provisions of the National Highways Act, 1956 (NHAI Act).
A. Brief Legislative Background
4. At this juncture, it is pertinent to briefly delve into the legislative
background of Section 3J of the NHAI Act vis-à-vis the 1894 Act
and the Right to Fair Compensation and Transparency in Land
Acquisition, Rehabilitation and Resettlement Act, 2013 (2013 Act).
5. The erstwhile 1894 Act facilitated the acquisition of land by the
Government for public purposes, outlining a process that included
the identification of land, issuance of a notification announcing the
intent to acquire, followed by inquiries and hearings to determine
the compensation payable to landowners. Additionally, the 1894 Act
provided for the grant of ‘solatium’ and ‘interest’ under Sections 23
and 28. For a considerable period, the NHAI Act operated alongside
the 1894 Act, with its provisions being pari materia to those of the
latter.
6. Be that as it may, Section 3J of the NHAI Act has been fraught with
controversy from its very inception. Section 3J, along with several
other provisions, were inserted into the NHAI Act vide the National
Highways Laws (Amendment) Act, 1997 (1997 Amendment),
with the objective of ‘creating an environment to promote private
investment in National Highways, to speed up construction of
highways and to remove bottlenecks in their proper management’.
In this regard, one of the impediments to the speedy implementation
of highway projects was recognised to be the inordinate delay in
the acquisition of land.
7. Accordingly, the NHAI Act was amended, with a number of measures
undertaken to accelerate the procedure of acquisition, whereby a
determination of compensation would be made by the Competent
Authority, and if not accepted by either party, it would then be
determined by an arbitrator appointed by the Central Government.
In addition, this newly introduced process did not envisage either
‘solatium’ or ‘interest’ and rather declared through Section 3J that
‘nothing in the Land Acquisition Act, 1894 shall apply to an acquisition
under this Act’.
[2025] 2 S.C.R. 381
Union of India & Ors. v. Tarsem Singh & Ors.
8. Upon its incorporation and coming into force, several High Courts
began to strike down Section 3J of the NHAI as unconstitutional in
the light of its effect of treating similarly situated individuals differently.
It was first struck down by the Karnataka High Court on 11.10.2002
in the case of Lalita v. Union of India3 and then subsequently on
28.03.2008 by the Punjab and Haryana High Court in Golden Iron
and Steel (supra). This trend continued to be followed by the Madras
High Court in T. Chakrapani v. Union of India.4
9. Meanwhile, the 2013 Act came into force with effect from 01.01.2014
and by the promulgation of Amendment Ordinance 9 of 2014,
the 2013 Act was amended from 01.01.2015, thereby making its
provisions applicable to numerous enactments, including the NHAI
Act. Subsequently, upon the lapsing of the Ordinance, a notification
dated 28.08.2015 was issued under Section 105, read with Section
113, wherein it was specified that the provisions of the 2013 Act
would apply to acquisitions carried out under the NHAI Act.
10. Thereafter, a batch of appeals challenging the decision in
T. Chakrapani (supra) were disposed of by this Court on 21.07.2016,
following a statement made by the then Solicitor General of India
that ‘solatium’ and ‘interest’ would be paid on acquisitions made
under the NHAI Act.5 However, the batch of appeals challenging the
decision of the Punjab and Haryana High Court in Golden Iron and
Steel (supra) remained pending. In two other appeals, challenging
the decisions of the Delhi High Court and the Punjab and Haryana
High Court, this Court disposed them off, holding that ‘solatium’ and
‘interest’ would be awardable to cases pending as on the date of
the decision of the Punjab and Haryana High Court in Golden Iron
and Steel (supra) i.e. 28.03.2008.6
11. This prompted NHAI to withdraw the appeals challenging the decision
in Golden Iron and Steel (supra). In similar cases, the Madras High
Court also awarded payment of ‘solatium’ and ‘interest’.7 Thereafter,
the decision in Tarsem Singh (supra) was delivered by this Court,
3 Lalita v. Union of India, 2002 SCC Online Kar 569.
4 T. Chakrapani v. Union of India, 2011 SCC Online Mad 2881.
5 Civil Appeal Nos. 129-159/2014.
6 Sunita Mehra v. Union of India, (2019) 17 SCC 672.
7 Union of India v. M. Pachamuthu, WA Nos. 62-81/2019.
382 [2025] 2 S.C.R.
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making clear the legal position on the grant of ‘solatium’ and ‘interest’
vis-à-vis the NHAI Act.
12. As already iterated, this triggered a chain reaction of writ petitions
being filed across various High Courts by aggrieved landowners
whose lands had been acquired by the NHAI in the period between
1997 and 2015 and who had not been granted the benefit of ‘solatium’
or ‘interest’, seeking parity with those who were found entitled to
these statutory benefits prior to 1997 and post-2015. Since the
High Courts have restored parity in these cases, NHAI has sought
clarification of our judgement in Tarsem Singh (supra).
B. Contentions on behalf of the parties
13. Mr. Tushar Mehta, Learned Solicitor General of India, appearing
on behalf of the Applicant, NHAI, made the following submissions:
a) The judgment in Tarsem Singh (supra) is applicable
prospectively from the date of its pronouncement, i.e.,
19.09.2019, and not retrospectively from the date of enforcement
of the 1997 Amendment. Granting relief in cases that have
already been concluded is inconsistent with the principles laid
down by the Constitution Bench in Gurpreet Singh v. Union
of India.8
b) If the judgment in Tarsem Singh (supra) is applied retrospectively,
it would necessitate reopening all acquisitions made by the NHAI
between 1997 and 2015. Consequently, the Government would
be obligated to compensate every claimant whose land was
acquired by the NHAI during this period.
c) Permitting the decision to operate retrospectively would lead to
an influx of mass litigation, requiring the reopening of closed
cases. This would have significant economic ramifications,
placing an additional burden of approximately Rupees 92.18
crores on the Public Exchequer for the payment of ‘interest’
and ‘solatium’ for the delayed period.
d) Reopening such cases would directly contravene the doctrine
of immutability, a fundamental principle which holds that a
8 Gurpreet Singh v. Union of India, (2006) 8 SCC 457.
[2025] 2 S.C.R. 383
Union of India & Ors. v. Tarsem Singh & Ors.
judgment, once attaining finality, becomes unalterable and
cannot be modified. Furthermore, any claims now raised by
private parties would be barred by the principles of delay and
laches.
14. Per contra, the counsel(s) representing the landowners refuted the
claims made by the NHAI and contended as follows:
a) Declaring the judgment in Tarsem Singh (supra) as prospective
would render redundant the entire exercise of ensuring parity,
given that the 2013 Act now governs the field, making the
grant of ‘solatium’ and ‘interest’ a requisite. Tarsem Singh
(supra) was delivered specifically with a view to address the
grievances of landowners who were denied the statutory benefit
of ‘solatium’ and ‘interest’ owing to the operation of Section 3J
of the NHAI Act.
b) Limiting the judgment to prospective application would result in
hostile discrimination, as landowners in Chakrapani (supra),
Tarsem Singh (supra), and similar cases have benefited from
the declaration of Section 3J of the NHAI Act as unconstitutional.
Conversely, other similarly situated landowners would be
deprived of the same relief, leading to inequality that undermines
the essence of Article 14 of the Constitution.
c) The instant Application seeking clarification represents a second
attempt to evade impending liability. This Court, in Tarsem
Singh (supra), has already addressed the precedent set in
Sunita Mehra (supra), unequivocally holding that the benefit
of ‘solatium’ and ‘interest’ must be extended to all cases arising
between 1997 and 2015, based on the categorical admission
by the Union of India itself.
d) The clarification sought through this Application, if entertained,
would effectively amount to a review of the decision in Tarsem
Singh (supra). It would also enable the Government to withdraw
from its previously stated position, wherein it had agreed to
extend the benefit of ‘solatium’ and ‘interest’.
C. Issues
15. As previously elaborated, the singular issue prompting filing of the
instant Application is to determine definitively whether the judgment
384 [2025] 2 S.C.R.
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in Tarsem Singh (supra) is applicable prospectively or extends
retrospectively.
D. Analysis
16. At the outset, it is essential to briefly refer to the ratio espoused in
Tarsem Singh (supra), which, after considering the relevant facts,
applicable laws, and precedents, held that Section 3J of the NHAI
Act, by excluding the applicability of the 1894 Act and thereby denying
‘solatium’ and ‘interest’ for lands acquired under the NHAI Act, is
violative of Article 14 of the Constitution. To this end, the decision
in Tarsem Singh (supra) took notice of the eleven grounds raised
on behalf of the NHAI and the Union of India, and dealt with those
grounds by segregating the appeals therein into eleven groups and
outlining them in seriatim.
17. Regardless, the prayer in the instant Application expressly seeks
clarification that the decision in Tarsem Singh (supra) should be
deemed to operate prospectively only. However, in our considered
view, granting such a clarification would effectively nullify the very relief
that Tarsem Singh (supra) intended to provide, as the prospective
operation of it would restore the state of affairs to the same position
as it was before the decision was rendered.
18. We say so for the reason that the broader purpose behind Tarsem
Singh (supra) was to resolve and put quietus upon the quagmire
created by Section 3J of the NHAI Act, which led to the unequal
treatment of similarly situated individuals. The impact of Section
3J was short-lived, owing to the applicability of the 2013 Act upon
the NHAI Act from the date of 01.01.2015. As a result, two classes
of landowners emerged, devoid of any intelligible differentia: those
whose lands were acquired by the NHAI between 1997 and 2015,
and those whose lands were acquired otherwise.
19. This must be viewed in the light of the principle that when a provision
is declared unconstitutional, any continued disparity strikes at the core
of Article 14 and must be rectified, particularly when such disparity
affects only a select group. To illustrate, rendering the decision in
Tarsem Singh (supra) as prospective would create a situation where
a landowner whose land was acquired on 31.12.2014 would be
denied the benefit of ‘solatium’ and ‘interest’, whereas a landowner
whose land was acquired the very next day, 01.01.2015—the date
[2025] 2 S.C.R. 385
Union of India & Ors. v. Tarsem Singh & Ors.
on which the Ordinance was promulgated, to read the 2013 Act into
the NHAI Act, would be entitled to these statutory benefits.
20. Be that as it may, even if we were to assume that the decision in
Tarsem Singh (supra) suffers from the vice of vagueness, the
absence of a judicial directive or an explicit legislative mandate
should not result in the creation of an artificial classification among
a homogeneous group by the same State exercising powers under
the same Statute. In this specific instance, the landowners have no
discretion or choice regarding the date of land acquisition or the
surrender of possession. Thus, both equity and equality demand
that no such discrimination be permitted, as allowing it would be
unjust.
21. That being so, the decision in Tarsem Singh (supra) also cannot
be assailed on the grounds that it opens a Pandora’s Box or
contravenes the doctrine of immutability, as it merely allows for
the grant of ‘solatium’ or ‘interest’, which are inherently embedded
as compensatory benefits under an expropriating legislation. This
exercise cannot be equated to reopening of cases or revisiting the
decisions that have already attained finality. Similarly, the restoration
of these twin benefits does not invite reconsideration of the merits
of a decided case, re-evaluation of the compensation amount, or
potentially declaring the acquisition process itself to be unlawful.
Instead, the ultimate outcome of Tarsem Singh (supra) is limited
to granting ‘solatium’ and ‘interest’ to aggrieved landowners whose
lands were acquired by NHAI between 1997 and 2015. It does not,
in any manner, direct the reopening of cases that have already
attained finality.
22. On the contrary, modifying or clarifying the judgment in Tarsem Singh
(supra) would lend itself to violating the doctrine of immutability,
undermining the finality of the decision. In fact, what the Applicant
seeks to achieve, indirectly, is to evade responsibility and further
delay the resolution of a settled issue where the directions given are
unequivocal—Quando aliquid prohibetur ex directo, prohibetur et per
obliquum i.e. ‘what cannot be done directly should also not be done
indirectly’. This Court has, on several occasions, disapproved of the
practice of filing Miscellaneous Applications as a strategic litigation
tactic aimed at neutralising judicial decisions and seeking a second
opportunity for relief.
386 [2025] 2 S.C.R.
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23. In all fairness, the only defense that may perhaps seem appealing
is the claim of a financial burden amounting to Rupees 100 crores.
However, this argument does not persuade us for several reasons:
First, if this burden has been borne by the NHAI in the case of
thousands of other landowners, it stands to reason that it should
also be shared by the NHAI in this instance, in order to eliminate
discrimination. Second, the financial burden of acquiring land cannot
be justified in the light of the Constitutional mandate of Article 300A.
Third, since most National Highways are being developed under the
Public Private Partnership model, the financial burden will ultimately
be passed on to the relevant Project Proponent. Fourth, even the
Project Proponent would not have to bear the compensation costs
out of pocket, as it is the commuters who will bear the actual brunt
of this cost. Ultimately, the burden is likely to be saddled onto the
middle or upper-middle-class segment of society, particularly those
who can afford private vehicles or operate commercial ventures.
We are thus not inclined to entertain the plea for prospectivity on
this limited tenet.
24. Lastly, as regards the decision in Sunita Mehra (supra), which
is claimed to have prohibited the grant of ‘solatium’ or ‘interest’
in concluded cases, we find that this position has already been
addressed and clarified in Tarsem Singh (supra). Given that the
Government, through the then Solicitor General, had conceded
this issue at that time, it cannot now retract its stance and seek to
reargue the same bone of contention. Hence, this assertion too,
stands rejected.
E. Conclusion
25. In view of the foregoing analysis, we find no merit in the contentions
raised by the Applicant, NHAI. We reaffirm the principles established
in Tarsem Singh (supra) regarding the beneficial nature of granting
‘solatium’ and ‘interest’ while emphasising the need to avoid creating
unjust classifications lacking intelligible differentia. Consequently, we
deem it appropriate to dismiss the present Miscellaneous Application.
26. Leave is granted in the other connected matters, and all the appeals
are disposed of with a direction to the Competent Authority to
calculate the amount of ‘solatium’ and ‘interest’ in accordance with
the directions issued in Tarsem Singh (supra). In this context, the
[2025] 2 S.C.R. 387
Union of India & Ors. v. Tarsem Singh & Ors.
appeal arising out of SLP (C) Diary No. 52538/2023 is dismissed, as
the challenge therein pertains to the High Court’s refusal to award
Additional Market Value as another component of the compensation,
while ‘solatium’ and ‘interest’ have already been granted.
27. Pending applications, if any, stand disposed of in the above terms.
Ordered accordingly.
Result of the case: Miscellaneous Application dismissed.
†
Headnotes prepared by: Ankit Gyan
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