- 9TH SEM MOOT COURT -

TEAM CODE: 13

BEFORE

THE HON’BLE HIGH COURT OF ALLAHABAD

9TH SEM MOOT COURT

FARMERS AND LANDOWNERS..................................(PETITIONERS)

v.

XYZ NATIONAL HIGHWAYS AUTHORITY AGENCY………(RESPONDENT)

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-TABLE OF CONTENTS-

List of Abbreviations..................................................................................................................3

Index of Authorities...................................................................................................................4

Statement of Jurisdiction............................................................................................................7

Summary of Facts......................................................................................................................8

Statement of Issues...................................................................................................................10

Summary of Arguments...........................................................................................................11

Arguments Advanced...............................................................................................................13

I. Whether the Act is in line with the constitutional provisions protecting the
fundamental rights of citizens, including the right to property and the
right to livelihood.

II. . The conflict between the public interest in promoting development and
the protection of individual rights, particularly the rights of landowners.

III. Whether the compensation offered to the farmers is adequate and

reflects the true value of their land and the potential losses they may
incur?

IV. Whether the proposed highway project aligns with sustainable

development goals and whether alternative approaches could minimize
the impact on the farmers?

Prayer.......................................................................................................................................19

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-LIST OF ABBREVIATIONS-

S.R. No. Abbreviation Expansion

1. And
&
2. All Allahabad

3. Anr. Another

4. Art. Article

5. Bom Bombay

6. u/s. Under Section

7. Cal Calcutta

8. Del Delhi

9. Govt. Government

10. Ltd. Limited

11. MP Madhya Pradesh

12. HC High Court

13. Ors Others

14. Pvt. Private

15. Sec Section

16. SC Supreme Court

17. SCJ Supreme Court Journal

18. TN Tamil Nadu

19. pg. Page number

20. UOI Union of India

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21. v. Versus

22. r/w. Read With

28. SCC Supreme Court Cases

-INDEX OF AUTHORITIES-
 Cases

S.No. Name

1. Vidya Devi vs The State Of Himachal Pradesh & Ors

2. Olga Tellis vs Bombay Municipal Corporation, AIR 1986 SC

180

3. Lavanya Kumari v. State of Bihar

4. Kameshwar Prasad & Others v. State of Bihar

5. Vellore Citizens Welfare Forum v. Union of India (1996)

6. Rudul Sah v. State of Bihar (1983

7. Kesavananda Bharati v. State of Kerala

8. Sudhir Kumar Saha v. State of West Bengal (2008)

9. Indore Development Authority v. Shailendra:

10. K.T. Plantation Pvt. Ltd. v. State of Karnataka (2011)

11. State of Gujarat v. Patel Raghav Natha (1971

STATUTES

 RIGHT TO FAIR COMPENSATION AND TRANSPARENCY IN LAND ACQUISITION,

REHABILITATION AND RESETTLEMENT ACT, 2013

 CONSTITUTION OF INDIA, 1950

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ARTICLES:

 Article 300A, CONSTITUTION OF INDIA, 1950

 Article 19 (1) (f), CONSTITUTION OF INDIA, 1950 (REPEALED NOW)

 Article 31, CONSTITUTION OF INDIA, 1950

 Article 300, CONSTITUTION OF INDIA, 1950

 THE 44th AMENDEMENT ACT, 1978

 ARTICLE 21, CONSTITUTION OF INDIA, 1950

SECTIONS:

 Section 2 of RIGHT TO FAIR COMPENSATION AND TRANSPARENCY IN LAND

ACQUISITION, REHABILITATION AND RESETTLEMENT ACT, 2013

 Section 4-9,RIGHT TO FAIR COMPENSATION AND TRANSPARENCY IN LAND

ACQUISITION, REHABILITATION AND RESETTLEMENT ACT, 2013

 Section 26, RIGHT TO FAIR COMPENSATION AND TRANSPARENCY IN LAND

ACQUISITION, REHABILITATION AND RESETTLEMENT ACT, 2013

 Section 27, RIGHT TO FAIR COMPENSATION AND TRANSPARENCY IN LAND

ACQUISITION, REHABILITATION AND RESETTLEMENT ACT, 2013

 Section 31, RIGHT TO FAIR COMPENSATION AND TRANSPARENCY IN LAND

ACQUISITION, REHABILITATION AND RESETTLEMENT ACT, 2013

BOOKS AND LEGAL DATABASES

 www.Manupatra.com

 www.SCCOnline.com

 www.Westlaw.com

 www.HeinOnline.com
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-STATEMENT OF JURISDICTION-

The Plaintiff appear before the Hon’ble High Court of Allahabad under Section 63 of
Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and
Resettlement Act, 2013 read with Article 226 of Constitution of India , 1950.

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-SUMMARY OF FACTS-

1. XYZ National Highway Authority Agency in its official gazette dated 24-09-2023,
notified to acquire a large tract of agricultural land to construct a new six-lane
highway connecting two major cities, and to purchase the marked required piece of
land of approximately 1000 acres directly from the farmers along the Greater Noida
Expressway for developing new industrial sectors.

2. In the notification it is given that the Ram Nagar district administration will be the
Nodal executing authority with XYZ to acquire the agricultural land for the project
under The Land Acquisition Act of 2013.

3. The acquisition started accordingly in December 2013. The same was halted as
farmers and land owners of the proposed project land protested against the
acquisition by the authority as the compensation amount offered to affected farmers
and land owners at the rate of ₹3,324 per square meter (sq.) was much lower than the
market value of the land proposed to be acquired.

4. However, the notices were issued to farmers and landowners and acquisition process
started, but it was observed that the some of the farmers and landowners notified did
not consent and adhered to the notices issued for acquisition process by the authority
claiming that the compensation offered by the authority is inadequate and that the
Social Impact Assessment process conducted was flawed.

5. It is also noted that the land in question is primarily owned by a group of farmers
who have been cultivating it for generations. The main contention of the farmers and
landowners is that the acquisition process in question not only deprives them of their
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livelihood and constitutional rights.

6. According to the states presented by the concerned authority of the project, out of 950
acres of minimum required land to complete the project 650 acres have been already
acquired and out of which 630 acres have been acquired for completing the project in
sectors 14, 15,16 & 20 falling between the Yamuna and Noida- Greater Noida
expressway. Around 300 or more of the proposed and notified land is reqd. To
complete the basic infrastructure works of the pending project including roads, parks
etc.

7. The farmers and the land owners (of the land already acquired and proposed to be
Acquired) have challenged the notification for acquisition under The Land
Acquisition Act of 2013, notified by XYZ National Highway Authority Agency in its
official gazette dated 24-09-2023.

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-STATEMENT OF ISSUES-

Issue 1

Whether the Act is in line with the constitutional provisions protecting the fundamental
rights of citizens, including the right to property and the right to livelihood?

Issue 2

The conflict between the public interest in promoting development and the protection of
individual rights, particularly the rights of landowners.

Issue 3

Whether the compensation offered to the farmers is adequate and reflects the true value
of their land and the potential losses they may incur?

Issue 4

Whether the proposed highway project aligns with sustainable development goals and
whether alternative approaches could minimize the impact on the farmers?

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-SUMMARY OF ARGUMENTS-

ISSUE 1: Whether the Act is in line with the constitutional provisions

protecting the fundamental rights of citizens, including the right to
property and the right to livelihood?

The act in question is not as per the theme of the Indian constitution, as it falls behind on
various aspects which are pivotal and holds utmost importance, when it comes to the rights
of the individual/ groups who’s properties are acquired.

The act does not take into the consideration about the livelihood, which in turn not only
affect that individual but also the upcoming generations. Moreover the act is also
discriminatory when it comes to compensation vis-à-vis Rural Property and urban property.

ISSUE 2: The conflict between the public interest in promoting

development and the protection of individual rights, particularly the rights
of landowners.

The petitioners, representing farmers and landowners, assert that the conflict between public
interest in promoting development and the protection of individual rights, particularly the
rights of landowners, is pronounced in the context of acquiring land for building a six-lane
national highway connecting two major cities. Article 21 of the Constitution guarantees the
right to life and livelihood. It is argued that acquiring land for a national highway should not
jeopardize the livelihoods of farmers and landowners, emphasizing the need for a balance
between development and the preservation of fundamental rights.

The petitioners contend that acquiring land for the national highway should not infringe upon
this constitutional right. The petitioners argue for a careful and rights-centric approach to
land acquisition for the national highway, citing specific provisions of the Land Acquisition
Act and constitutional guarantees. They underscore the principles of fair compensation,
community consent, and the right to livelihood, seeking a balance between development
goals and the protection of individual rights.

ISSUE 3: Whether the compensation offered to the farmers is adequate

and reflects the true value of their land and the potential losses they may
incur?

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It is contend that the Hon’ble Court must address the inadequacy of compensation for
farmers, considering not just economic losses but also the emotional and cultural ties to their
land. The flawed Social Impact Assessment warrants review, and adherence to Sections 26
and 28 of the Land Acquisition Act is essential for fair compensation. Upholding
constitutional rights and emphasizing rehabilitation under the LARR Act are imperative for a
just resolution that respects farmers’ livelihoods and their constitutional entitlements.

-ARGUMENTS ADVANCED-

I. That the Act is not in line with the constitutional provisions protecting the
fundamental rights of citizens, including the right to property and the right
to livelihood

This act do not define the public purpose appropriately and in many area the definition is vague
and un clear.

Right to property even though removed from part 3 still holds importance in the constitution
and must be looked into carefully by the central as well as state government. On January 8,
2020, a Supreme Court bench comprised of Justices Ajay Rastogi and Indu Malhotra ruled in the
case of Vidya Devi vs The State Of Himachal Pradesh & Ors 1that the Right to Property is a
human right.

The act in question does not take into consideration livelihood, which is a significant factor to
be taken into consideration while acquiring of the land of an individual or a group. Supreme
court has on various occasions highlighted the importance of the same.

Article 21 lies at the very heart of our constitution, as it provides that, “No person shall be
deprived of his life or personal liberty except according to procedure established by law”. It is
this fundamental right that protects the life and liberties of its people. In Olga Tellis vs Bombay
Municipal Corporation, AIR 1986 SC 180, the court established that the right to livelihood is
borne out of the right to live, as no person can live without a livelihood. In this case, fair and
equal access to the land and its resources, is needed to protect their livelihood. Therefore, in
this case, the land acquisition drive works contrary to the constitution’s Right to Life. Land
acquisition and tempting offers of financial compensation seem to be increasingly common
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ways to deprive people of their livelihood and consequently, their right to life. Moreover in the
instance case the compensation is also not just and reasonable it is far lesser then the market
value.

Now therefore the act does not comply with the provisions of the constitution and also does
not comply with the natural justice.

1
Jan 2020 SCC

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II. The conflict between the public interest in promoting development and the
protection of individual rights, particularly the rights of landowners.

The petitioners, representing farmers and landowners, assert that the conflict between
public interest in promoting development and the protection of individual rights,
particularly the rights of landowners, is pronounced in the context of acquiring land for
building a six-lane national highway connecting two major cities.

The petitioners invoke Article 21 of the Constitution, which guarantees the right to life and
livelihood. It is argued that acquiring land for a national highway should not jeopardize the
livelihoods of farmers and landowners, emphasizing the need for a balance between
development and the preservation of fundamental rights. The petitioners contend that
acquiring land for the national highway should not infringe upon this constitutional right. In
the case of Olga Tellis v. Bombay Municipal Corporation1 case, the Supreme Court
recognized the right to livelihood as an integral part of the right to life.

It is stressed the importance of a rigorous examination of the public purpose behind

acquiring land for the national highway. The government must demonstrate a genuine
need for the project, aligning it with the broader interests of the public.
In case of Lavanya Kumari v. State of Bihar2 the court emphasizes that the
government's power of eminent domain is not absolute and must be exercised
judiciously, particularly when it comes to displacing individuals for public projects.
Section 2 of the Act defines "public purpose," and In the case of Kameshwar Prasad &
Others v. State of Bihar3 the court emphasized that the acquisition must be for a bona
fide public purpose and not for the benefit of private individuals. Therefore the
government's power to acquire land should be exercised judiciously, especially when it
involves displacing individuals for a national highway project.
It is invoked that the environmental mitigating measures should be taken into
consideration.

The case of Vellore Citizens Welfare Forum v. Union of India (1996) established that
environmental concerns are integral to public purpose, and any action causing
environmental harm can be challenged. Section 5 of the land acquisition Act 2013
outlines that the Collector must assess the social impact and ecological impact of the
project during the preparation of the Rehabilitation and Resettlement Scheme and to
examine the conflict between the individual and public interest.

1
1985 SCC ( 3) 545
2
2020 SCC (6) 755
3
1952 1 SCR 889
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The land acquisition Act 2013 under sec.4 requires obtaining the consent of affected
families and conducting a Social Impact Assessment for land acquisition. The petitioners
contend that these provisions are crucial, especially when acquiring land for a major
infrastructure project. They argue that community input and consent should be integral to
the decision-making process, ensuring that the interests of the affected individuals are
duly considered. Sections 4 to 9 of the Act outline the process of land acquisition,
including the right of the landowner to be heard and object to the acquisition. Assert that
proper notice and opportunity for objections are essential to safeguard individual rights.
The decision in Rudul Sah v. State of Bihar (1983) underscored the importance of
giving affected parties an opportunity to be heard, ensuring due process is followed for
acquiring land.

Section 3(f) of the Act mandates the consideration of alternative sites. The authorities
must thoroughly examine alternatives and choose the one that minimizes the impact on
landowners. The judgment in Sudhir Kumar Saha v. State of West Bengal (2008)
supported the argument that authorities must consider alternative sites and choose the one
causing the least harm to landowners.

Article 300A of the Constitution of India recognizes the importance of protecting the
interests of landowners. The right to property is a fundamental right, and any acquisition
must be in accordance with the law. The case of K.T. Plantation Pvt. Ltd. v. State of
Karnataka (2011) emphasized the need to balance the right to property with public
interest, ensuring fairness in the acquisition process.

Section 31 of the LAND ACQUISITION Act, 2013 considers the extent of the area, the
value of the land, and the damage sustained by the person interested. It is surmised that
the impact on the livelihood of farmers should be proportionate and not disproportionate
to the purported public purpose.
State of Gujarat v. Patel Raghav Natha (1971) highlighted that deprivation of
livelihood without reasonable alternatives could render the acquisition
excessive.
The farmers and landowners argue that the land acquisition process must respect and
protect their individual rights, particularly in the context of public purpose, as defined by
the Land Acquisition Act, 2013.

In addition to the Act, the petitioners draw on relevant case laws:

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Kesavananda Bharati v. State of Kerala4: This landmark case reinforces the idea that
development initiatives must respect the basic structure of the Constitution. The
petitioners argue that any acquisition of land for development must align with
constitutional principles, safeguarding the fundamental rights of citizens.

Indore Development Authority v. Shailendra5: This case emphasizes the importance of

adhering to compensation and rehabilitation principles outlined in the Land Acquisition
Act. The petitioners use this case to argue that any deviation from these principles
compromises the rights of landowners and goes against the spirit of the Act.

In summary, the petitioners argue for a careful and rights-centric approach to land
acquisition for the national highway, citing specific provisions of the Land Acquisition
Act and constitutional guarantees. They underscore the principles of fair compensation,
community consent, and the right to livelihood, seeking a balance between development
goals and the protection of individual rights.

III. Whether the compensation offered to the farmers is adequate and reflects the true
value of their land and the potential losses they may incur?

The counsel to the Hon’ble court that the compensation paid to the farmers is not
sufficient to reflect the true value of their land and the potential losses they may suffer
humbly submits it. It is argued that the economic impact on their livelihoods is substantial
and that the compensation should be revised to reflect the actual value of the land.
The affected farmers and landowners, many of who have cultivated the land for
generations, argue that the compensation amount fails to consider the emotional and
cultural attachment they have to the land. It is argued that the disruption caused by the
acquisition not only deprives them of their livelihood but also infringes upon their
constitutional rights.
Moreover, the farmers challenge the credibility of the Social Impact Assessment process,
alleging flaws and biases in its execution. They argue that the assessment failed to
accurately capture the true extent of the impact on their lives, and the proposed
compensation is insufficient to mitigate the losses incurred due to the displacement.
The issue of insufficient compensation for land acquired from farmers is a matter of
concern that has been raised many times. Several key considerations must be weighed:
Economic loss: Acquiring land from farmers often results in the loss of their primary source
of income. Farmers invest their time, labor, and resources in cultivating the land, and it serves
as their livelihood. The compensation received should account for the economic loss suffered
by farmers and provide them with an alternative means of sustenance.
Market value: The compensation provided to farmers should be based on the prevailing
market value of the land. It is essential to ensure that receiving compensation that does not
reflect the actual worth of their land does not disadvantage farmers. Fair compensation should
consider factors such as location, productivity, fertility, and potential for future development.
Section 26 under The Land Acquisition Act of 2013
Determination of market value of land by Collector.–(1) The Collector shall adopt the
following criteria in assessing and determining the market value of the land, namely:— (a)
the market value, if any, specified in the Indian Stamp Act, 1899 (2 of 1899) for the

4
AIR 1973 SC 461
5
(2020) 8 SCC 129
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registration of sale deeds or agreements to sell, as the case may be, in the area, where the land
is situated; or
(b) the average sale price for similar type of land situated in the nearest village or nearest

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vicinity area; or (c) consented amount of compensation as agreed upon under sub- section (2) of
section 2 in case of acquisition of lands for private companies or for public private partnership
projects, whichever is higher: Provided that the date for determination of market value shall be
the date on which the notification has been issued under section 11.
In the Present case the compensation provided to farmers is not adequate, as the authority
didn’t follow the criteria in assessing and determining the market value of the land so the
court should also consider it.
Section 27 under The Land Acquisition Act of 2013
27. Determination of amount of compensation.–The Collector having determined the market
value of the land to be acquired shall calculate the total amount of compensation to be paid to
the land owner (whose land has been acquired) by including all assets attached to the land.
In the present case the Collector failed to determine the market value of the land to be
acquired as the market value of the land is more than the above said compensation.
Section 28 under The Land Acquisition Act of 2013
28. Parameters to be considered by Collector in determination of award.–In determining the
Amount of compensation to be awarded for land acquired under this Act, the Collector shall
take into consideration— firstly, the market value as determined under section 26 and the
award amount in accordance with the First and Second Schedules; 25 secondly, the damage
sustained by the person interested, by reason of the taking of any standing crops and trees
which may be on the land at the time of the Collector's taking possession thereof;
thirdly, the damage (if any) sustained by the person interested, at the time of the
Collector's taking possession of the land, by reason of severing such land from his other
land; fourthly, the damage (if any) sustained by the person interested, at the time of the
Collector's taking possession of the land, by reason of the acquisition injuriously
affecting his other property, movable or immovable, in any other manner, or his earnings;
fifthly, in consequence of the acquisition of the land by the Collector, the person interested is
compelled to change his residence or place of business, the reasonable expenses (if any)
incidental to such change; sixthly, the damage (if any) bona fide resulting from diminution of
the profits of the land between the time of the publication of the declaration under section 19
and the time of the taking possession of the land; and seventhly, any other ground which may
be in the interest of equity, justice and beneficial to the affected families.
M B Nandeesh vs Project Director on 14 December, 2022, In this case, the Karnataka
High Court held that adequate compensation must be provided to displaced persons
affected by land acquisition and that the State cannot deprive individuals of their property
without providing adequate compensation, rehabilitation, and resettlement benefits.
In the present case the collector didn’t consider the parameters in determination of award
as in determining compensation for acquired land, the Collector considers market value,
damage to standing crops, severance of land, impact on other properties, relocation
expenses, diminished profits, and any other grounds promoting equity and justice, as
specified in Sections 26 and 28 of the Act.
Emotional and social impact: Land holds immense emotional and social value for
farmers, as it may have been in their families for generations. The compensation should
acknowledge the emotional attachment and the social displacement resulting from the
loss of land. Adequate compensation can help farmer’s transition and rebuild their lives in
the new circumstances.
Rehabilitation and resettlement: Apart from monetary compensation, the government
should also provide proper rehabilitation and resettlement support to farmers. This
includes ensuring access to essential amenities, infrastructure, education, healthcare, and
livelihood opportunities in the new location. The costs associated with rehabilitation
should be factored into the compensation provided. Land Acquisition,
Rehabilitation and
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Resettlement (LARR) Act 2013

In India, the Right to Fair Compensation and Transparency in governs land acquisition.
Land Acquisition, Rehabilitation and Resettlement (LARR) Act 2013. This Act replaced
the Land Acquisition Act, 1894.
The main purpose for enacting this Act is to provide certain rules and regulations for
acquiring land and also for granting compensation, rehabilitation and resettlement to the
affected families. The Act mainly emphasizes to provide adequate compensation to
individuals whose properties are acquired as per the direction of the Government. The
Central or State Government has power to acquire the land even if it is against the will of
the individual, but they have to make sure that the aggrieved individuals are compensated
to the loss suffered by them. The property acquired under the Act should be used only for
public welfare.
In the case of The Caritas India vs. Union Of India on 3 July 2019, where the court
emphasized the importance of fair compensation and proper rehabilitation and directed
the authorities to strictly adhere to the provisions of the Act.
Constitutional rights: Farmers have a legal right to property under Article 300A of the
Indian Constitution, which ensures that no person shall be deprived of his or her property
except by the authority of law. Any acquisition of land must be just, fair, and reasonable, with
compensation that adequately reflects the value of their property.
So the compensation paid to farmers must accurately reflect the true value of their land and
the potential losses incurred. It is important to advocate for fair and just compensation to
protect the rights and livelihoods of farmers affected by land acquisition.

Section 30 of Land Acquisition Act 2013.

The Collector having determined the total compensation to be paid, shall, to arrive
at the final award, impose a amount equivalent to one hundred per cent of the
compensation amount
2) The Collector shall issue individual awards detailing the particulars of compensation
payable and the details of payment of the compensation as specified in the First Schedule.
(3) In addition to the market value of the land provided under section 26, the Collector shall,
in every case. Award an amount calculated at the rate of twelve per cent. per annum on such
market value for the period commencing on and from the date of the publication of the
notification of the Social Impact Assessment study under sub-section (2) of section 4, in
respect of such land, till the date of the award of the collector or the date of taking possession.

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-PRAYER-
Wherefore in the light of the arguments advanced and authorities citied, the petitioners
humbly submit that the Hon'ble Court may be pleased to adjudge and be pleased to grant
that:

1. To declare the said act as constitutionally invalid.

2. To set aside, the notification of acquisition by the respondent.

3. To direct the respondent authorities to provide enhanced valid compensation to

the claimants within reasonable time.

4. To uphold the project liable of being unaligned with established crucial

sustainable goals.

5. To grant any other relief to the petitioners that the court finds justiciable in the
pursuit of Justice.

Counsel

of

Petitioner

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