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Dhanalakshmi v. The District Collector and Land Acquisition Arbitrator

Madras HC26 Nov 2025WP(MD)/26023/2025

Case brief

AI extract

What is this about?

Maintainability of writ petition against arbitral award in National Highways Act 1956 land acquisition; District Collector as Land Acquisition Arbitrator; self-contained dispute resolution mechanism; alternative remedy under Section 34 of the Arbitration and Conciliation Act 1996; certiorari under Article 226 declined; exclusion of writ pendency period for computation of limitation; bona fide prosecution from September 2025; Dindigul District; NH 209; National Highways Authority of India; no costs.

What did the court decide?

Writ petition not entertained on merits and disposed of, with a recording that the petitioner is entitled to exclusion of the period of pendency of the writ petition (lodged September 2025) for computation of limitation; no costs. ¶22

Dhanalakshmi Vs The District Collector and Land Acquisition… — Arbitration | Madras HC (2025)

What the court decided

AI extract

Outcome

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Issue for consideration

Whether the writ petition challenging the arbitral award passed by the District Collector as Land Acquisition Arbitrator under the National Highways Act 1956 should be entertained, notwithstanding the challenge mechanism in terms of Section 34 of the Arbitration and Conciliation Act, 1996. +1 more

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Court's answer

The NH Act provides for the District Collector to function as an Arbitrator and for a challenge in terms of Section 34 of the Arbitration and Conciliation Act, 1996; these provisions constitute a self-contained dispute resolution mechanism, and therefore the Court is not inclined to entertain the writ petition.

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Ratio / Principle

Having recorded that the writ petition was lodged and prosecuted bona fide from September 2025, the Court directs that the petitioner is entitled to the exclusion of the period of pendency of this writ petition for computation of limitation, and disposes of the writ petition with no costs.

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Detailed headnote1 paragraphs

Writ petition under Article 226 seeking certiorari to quash an arbitral award dated 31.07.2024 (Na.Ka.No.1732156/2024/E1) passed by the District Collector, Dindigul, functioning as Land Acquisition Arbitrator in acquisition proceedings under the National Highways Act 1956: HELD, the NH Act provides for the District Collector to function as an Arbitrator and for a challenge in terms of Section 34 of the Arbitration and Conciliation Act, 1996, and these provisions constitute a self-contained dispute resolution mechanism; the Court therefore declined to entertain the writ petition. Recording that the petition was lodged and prosecuted bona fide from September 2025, the Court disposed of the writ petition by directing that the petitioner is entitled to exclusion of the period of its pendency for computation of limitation, with no costs.

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W.P.(MD)No.26023 of 2025

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BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT

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DATED :26.11.2025

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CORAM

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THE HONOURABLE MR.JUSTICE SENTHILKUMAR RAMAMOORTHY

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W.P.(MD)No.26023 of 2025

Dhanalakshmi

... Petitioner

Vs.

The District Collector and Land Acquisition Arbitrator, Dindigul District, Dindigul.

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The Competent Authority and Special District Revenue Officer, (Land Acquisition) Dindigul District, Dindigul.

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The Project Director, NH 209, National Highways Authority of India, Dindigul.

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The Special Tahsildar, Land Acquisition, Ottanchathram, Dindigul District. ... Respondents PRAYER : Petition filed under Article 226 of the Constitution of India praying for issuance of Writ of Certiorari, calling for the records pertaining to the impugned order in Na.Ka.No.1732156/2024/E1 dated 31.07.2024 issued by the 1st respondent and quash the same.

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https://www.mhc.tn.gov.in/judis

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W.P.(MD)No.26023 of 2025

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For Petitioner : Mr. N.Ananda Kumar

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For Respondents :Mr.P.Thambidurai Government Advocate for R1, R2 & R4 Mr.B.Naveen Kumar for Mr.Su.Srinivasan for R3

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O R D E R

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An arbitral award dated 31.07.2024 in relation to acquisition proceedings under the National Highways Act 1956 (the NH Act) is challenged in this writ petition.

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The NH Act provides for the District Collector to function as an Arbitrator and for a challenge in terms of Section 34 of the Arbitration and Conciliation Act, 1996. In view of the provisions thereof, which constitute a self- contained dispute resolution mechanism, I am not inclined to entertain the writ petition. The present writ petition was lodged and prosecuted bona fide from September 2025. Therefore, by recording that the petitioner is entitled to the exclusion of the period of

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pendency of this writ petition for computation of limitation, the writ petition is disposed of. No costs.

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26.11.2025 NCC : Yes/No Internet : Yes/No Index : Yes/No PKN

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https://www.mhc.tn.gov.in/judis

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W.P.(MD)No.26023 of 2025

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