The Tripura High Court has held that additional land required for a public project cannot be acquired merely by issuing a corrigendum to an earlier land acquisition notification, particularly after the original acquisition proceedings have concluded and compensation has been paid. The Court directed the authorities to return 0.019 acres of land to the petitioner, while permitting them to initiate fresh acquisition proceedings in accordance with law.

Justice Dr. T. Amarnath Goud remarked that: “This Court is of the view that the said corrigendum issued cannot be treated as notification under the Statute… In the event, if the respondents require more land they could have initiated proceedings again for whatever extent they require the same.”

Background

The petitioner, Gitanjali Saha, challenged the acquisition of her remaining 0.019 acres of land in Mouja Barjala, West Tripura. Earlier, 0.021 acres out of her 0.040-acre holding had been acquired for the Lichubagan–Agartala Airport four-lane road project, for which she received compensation of ₹7,94,565. After the road project was completed, the authorities issued a corrigendum dated August 12, 2022 seeking to acquire the remaining 0.019 acres.

The petitioner contended that the additional land could not be acquired through a corrigendum and that fresh statutory acquisition proceedings were required. The Land Acquisition Collector, however, upheld the acquisition on March 25, 2025, following which she approached the High Court.

The Tripura High Court held that the August 12, 2022 corrigendum could not be treated as a valid statutory notification for acquiring the petitioner's additional 0.019 acres, as the original acquisition proceedings had already concluded and compensation had been paid.

The Court held that if the authorities required additional land, they were required to initiate fresh acquisition proceedings in accordance with law. It accordingly set aside the corrigendum and subsequent acquisition proceedings and directed the authorities to return the 0.019 acres to the petitioner.

Date of Decision: 17.09.2026