No Right to Job for Land Acquired

Source: Supreme Court  

Why in News? 

Recently, Justice Pankaj Mithal and Justice Prasanna B Varale dismissed a plea seeking a government job in exchange for land acquired in 1998, ruling that the Land Acquisition Act, 1894 provides only for monetary compensation—not employment—in such cases. 

• The Supreme Court held this in the matter of Sanjeev Kumar v State of Haryana and others (2025). 

What was the Background of Sanjeev Kumar v. State of Haryana and others (2025) Case? 

• The petitioner's family-owned agricultural land was acquired by the State Government in the year 1998 under the provisions of the Land Acquisition Act, 1894. 
• At the time of land acquisition in 1998, the petitioner was not even born and therefore had no direct involvement in the acquisition of proceedings. 
• Pursuant to the acquisition, the appropriate compensation was determined by the competent authority and was duly paid to the family members of the petitioner in accordance with the provisions of the Act. 
• The family accepted the compensation amount as awarded under the statutory framework of the Land Acquisition Act, 1894. 
• Nearly three decades after the acquisition, in the year 2025, the petitioner made an application to the State Government seeking appointment to government service on compassionate grounds. 
• The petitioner's claim for employment was premised on the ground that the same should be provided in lieu of the land which had been acquired from his family in 1998. 
• The petitioner contended that employment in government service was a consequential right flowing from the land acquisition and should be granted to compensate for the loss suffered by the family. 
• The concerned authorities rejected the petitioner's application for appointment, holding that there was no statutory provision or entitlement for grant of employment in lieu of acquired land. 
• Aggrieved by the rejection, the petitioner approached the High Court by way of a writ petition seeking direction to the authorities to provide him employment. 
• The High Court dismissed the writ petition, upholding the decision of the authorities and finding no merit in the petitioner's claim for employment. 
• Being dissatisfied with the High Court's decision, the petitioner filed a Special Leave Petition before the Supreme Court under Article 136 of the Constitution of India. 
• The petitioner submitted that even if there existed an administrative policy providing employment to families affected by land acquisition, he should be entitled to the benefit of such policy. 

What were the Court’s Observations? 

• The Supreme Court observed that under the provisions of the Land Acquisition Act, 1894, upon acquisition of land, the affected person or his family is entitled only to monetary compensation as prescribed under the statutory scheme. 
• The Court noted that there is no provision whatsoever in the Land Acquisition Act, 1894 for grant of employment or job in lieu of the acquired land. 
• The Bench observed that the statutory scheme of the Act envisages payment of adequate compensation as the complete and exhaustive remedy for deprivation of property rights through acquisition. 
• The Court held that once lawful compensation has been paid in accordance with the provisions of the Act, the State's obligation under the statute stands fully discharged and satisfied. 
• The Supreme Court observed that even if there existed any administrative policy decision at any point in time providing for grant of employment to persons affected by land acquisition, such policy cannot prevail over or override the express statutory provisions of the Land Acquisition Act. 
• The Court noted that administrative policies or executive decisions cannot confer rights which are not contemplated or provided for under the parent statute. 
• The Bench observed that the petitioner's claim for employment was filed after a substantial delay of more than 18 years from the date of framing of any such policy, rendering the claim stale and time barred. 
• The Court observed that the petitioner, who was not even born at the time of acquisition, had no vested right to seek employment on the basis of a transaction to which he was not a party. 
• The Supreme Court found no error, illegality, or perversity in the orders passed by the concerned authorities or in the judgment of the High Court dismissing the petitioner's claim. 
• The Court held that the authorities and the High Court had rightly rejected the claim for employment, as the same was neither sustainable in law nor supported by any statutory provision. 
• The Bench concluded that the family having already received and accepted the statutory compensation, no further relief or benefit could be claimed after nearly three decades of the acquisition. 
• The Supreme Court observed that entertaining such belated claims would set a dangerous precedent and would be contrary to the settled principles of land acquisition law and the doctrine of finality in legal proceedings. 

What Legal Provisions Were Referred? 

Land Acquisition Act, 1894: 

• The Land Acquisition Act, 1894 is the primary statutory framework governing acquisition of private land by the State for public purposes and provides for determination and payment of compensation to affected landowners. 
• Under the provisions of the Land Acquisition Act, 1894, upon acquisition of land, the affected person or his family is entitled only to monetary compensation as prescribed under the statutory scheme. 
• The Act envisages payment of adequate compensation as the complete and exhaustive remedy for deprivation of property rights through acquisition. 
• There is no provision whatsoever in the Land Acquisition Act, 1894 for grant of employment or job in lieu of acquired land. 
• Once lawful compensation has been paid in accordance with the provisions of the Act, the State's obligation under the statute stands fully discharged and satisfied. 
• Administrative policies or executive decisions cannot confer rights which are not contemplated or provided for under the parent statute, and such policies cannot prevail over or override the express statutory provisions of the Land Acquisition Act. 

Article 136 of the Constitution of India: 

• Article 136 of the Constitution of India confers special jurisdiction upon the Supreme Court to grant special leave to appeal from any judgement, decree, determination, sentence, or order in any cause or matter passed or made by any court or tribunal in the territory of India. 
• The petitioner invoked Article 136 by filing a Special Leave Petition before the Supreme Court challenging the High Court's judgement dismissing his writ petition seeking employment in lieu of acquired land.