Authority: Supreme Court of India

Order Date: 12 August 2026

Case Overview

  • Parties: National Highways Authority of India (Petitioner) vs. Tribhavan Kumar Jain & Ors. (Respondents).
  • The application (Misc. App. No. 2165/2026) arose from Civil Appeal No. 423/2025, which itself stemmed from SLP(C) No. 27299/2024.
  • The original order dated 16 January 2025 directed that 50 % of the compensation awarded to landowners could be released only upon furnishing a bank guarantee of a nationalised bank, with the remaining 50 % kept in a fixed deposit.
  • The petitioner sought to replace the bank‑guarantee requirement with “adequate security” such as title deeds/ownership documents of equivalent value, and to keep the remaining amount in FD until disposal of the appeal before the High Court.
  • The Court noted a parallel decision in Special Leave Petition (Civil) Diary No. 2998/2026 (NHAI v. Indian Acrylics Ltd.) where it had clarified that adequate security may be title deeds and need not be a bank guarantee.

Final Outcome

  • The Court held that requiring a bank guarantee from the landowners would be harsh and substituted the requirement with “adequate security” in the form of title deeds or ownership documents of equivalent value, to the satisfaction of the executing court.
  • The Miscellaneous Application was allowed; the interlocutory application was disposed of; any pending applications were ordered disposed of.
  • The direction that the remaining 50 % of the compensation continue to be invested in a fixed deposit with a nationalised bank, renewable until the High Court disposes of the appeal, remains unchanged.

Topics: Compensation Security, Land Acquisition, Judicial Modification