Thursday, 24 April 2014

A person who is not party before land acquisition officer can not be added as party before reference court

Ram Prakash Agarwal v. Gopi Krishan, (2013) 11 SCC 296


 Land Acquisition Act, 1894 
 Ss. 18, 30, 31 and 3(b) - Proceedings in Reference Court - Direct impleadment of or application for apportionment of
compensation by a third party (not a party in LA Act proceedings at any stage) - Impermissibility - Said impleadment or
application for apportionment, held, is impermissible - Said third party is not entitled to set aside award made by
Reference Court by seeking help of Or. 9 R. 13 r/w S. 151 CPC - Such inherent powers cannot be invoked by alleging
fraud on a party (as distinguished from fraud on a court) - Impugned High Court order setting aside the award of
Reference Court, therefore, set aside - Respondents given liberty to seek appropriate remedy by resorting to appropriate
proceedings as permissible under law,

   
 Civil Procedure Code, 1908 

 S. 151 - Inherent powers under - Applicability - Principles reiterated - Such powers can be used: (a) when CPC has no
remedy, (b) in a pending suit, (c) at the behest of persons who are parties to suit in a manner consistent with justice and
equity, (d) in case, a party is prejudiced, (e) in case of failure of justice, (f) in case of fraud on court (as distinguished from
fraud on a party), and (d) for consolidation of suits, where there are common questions of fact and law (not being a case
of misjoinder of parties) - But such powers cannot be used to re-open settled matters or to restrain the execution of a
decree at the instance of one who was not a party to suit - Said powers cannot be exercised in contravention of, or in
conflict with, or upon ignoring express and specific provisions of the law, (2013) 11 SCC 296-B 
   
 Civil Procedure Code, 1908 

 S. 151 and Or. 9 R. 13 - Exercise of inherent powers for setting aside of ex-parte decree - Scope of applicability,
clarified, 
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