Introduction:

In a recent ruling, the Supreme Court of India addressed a batch of land acquisition cases involving the Delhi government and its entities. The Court examined the application of the principle of res judicata in situations where public interest is at stake. The case stemmed from the Delhi government’s land acquisition process for the planned development of Delhi under the Land Acquisition Act, 1894.

Appellant Authorities:

The Delhi government authorities, represented by their counsel, argued that the decisions made in the first round of litigation should not be binding in the second round. They contended that the law had been altered by the Constitution Bench decision in *Indore Development Authority v. Manoharlal*, and thus, the principle of res judicata should not apply retrospectively. The authorities asserted that they were only formally impleaded in the first round and were not adequately heard, hence the previous decisions should not be binding.

Respondent Landowners:

On the other hand, the landowners argued that the principle of res judicata should apply to the cases. They emphasized that the acquiring authorities and the beneficiaries shared a common interest in the land acquisition for public purposes. Therefore, they argued that dismissal of a civil appeal by one authority in the first round should act as res judicata against the other authority in subsequent rounds of litigation.

Court’s Judgement:

The bench, comprising Justices Surya Kant, Dipankar Datta, and Ujjal Bhuyan, held that in cases involving public interest, a more flexible approach should be adopted. The Court observed that the principle of res judicata may not strictly apply when larger public interest is at stake. It noted that the Delhi government entities did not have conflicting interests, neither before the High Court nor before the Supreme Court. Therefore, the Court concluded that the previous decisions should not operate as res judicata to bar a decision in the lead matter and other appeals.