Bombay High Court, Aurangabad Bench (DB: Hiten S. Venegavkar, J., author; Smt. Vibha Kankanwadi, J.) | Neutral cit. 2026:BHC-AUG:7156-DB | 17.02.2026 | W.P. No. 3703 of 2025 with connected W.Ps. 3229, 5709, 8302, 13737, 13734, 13735, 13739, 13738, 13027, 13026, 13020, 13024, 13018, 13025, 13019, 13022, 13740 of 2025 — Agriculturists whose lands were acquired for State Highway (Special) No. 2A (8-lane Jalna–Nanded Super Expressway, extension of the Nagpur–Mumbai Samruddhi Highway) under the Maharashtra Highways Act, 1955 challenged (i) the Collector, Parbhani's communication dated 10.01.2025 conveying directions said to have been issued in the Hon'ble Chief Minister's review meeting of 09.01.2025 to pay compensation per the District Level Committee decision of 09.06.2023, and (ii) the award dated 29.09.2025 passed after a fresh notice under S.19B(6) dated 07.08.2025; they sought enforcement of the LAO's determination of 02/03.09.2024 (based on the April-2023 Joint Measurement Survey valuation reports) approved at the DLC meeting of 04.10.2024 and their consent letter of 07.01.2025, pleading promissory estoppel and attacking the 'second award'. HELD: (a) the dispute is essentially one of compensation methodology, not acquisition legality — vesting complete, acquisition unchallenged; (b) internal administrative decisions, DLC deliberations and RTI-obtained minutes cannot create enforceable rights; finality attaches only to a statutory determination/award recognizable under S.19B; (c) promissory estoppel cannot compel the State contrary to statute or freeze the process at a non-statutory stage; (d) the Collector's communication is not ipso facto unlawful interference absent demonstrable substitution of the LAO's independent satisfaction by executive command; (e) the 'second determination/second award' objection rests on an oversimplified reading — the authority is not functus officio where the process has not finally crystallized; (f) the second valuation report episode is, at highest, a curable procedural irregularity subsequently cured by hearings; (g) S.19B(8) arbitration is the primary forum for adequacy/methodology grievances; judicial review under Art.226 is confined to legality, jurisdiction and procedural fairness; the nomenclature ('award' vs 'determination') of the 29.09 document is immaterial. PETITIONS DISMISSED; quantum/methodology not examined; liberty reserved to pursue statutory remedies including arbitration; interim protection (order dt.15.10.2025) discontinued; possession may proceed subject to strict compliance with the 1955 Act/Rules including S.19P compensation-payment requirements.
