A) ABSTRACT / HEADNOTE

The judgment in Mahanadi Coal Fields Ltd. & Anr. v. Mathias Oram & Ors., [2025] 1 S.C.R. 158 : 2025 INSC 22, addresses the limited scope of the Claims Commission constituted by this Court to determine compensation and ancillary Rehabilitation & Resettlement (R&R) benefits arising from large-scale land acquisition for coal development. The Court refused further extension of the Commission’s term and denied directions that would require the Commission to reopen finalized determinations or to prepare PAF/PDF lists for remaining villages beyond the specific, narrowly-prescribed reassessment mandated by earlier orders.

The ruling reiterates that for four villages Tumulia, Jhupuranga, Ratansara, Kiripsara compensation must be re-determined only to the extent of the differential arising from the application of the First Schedule to the R&R Act, 2013 (i.e., market value, solatium and further interest), while determinations already approved by this Court for ten other villages have crystallised and cannot be reopened. The Court directed the Orissa High Court to promptly adjudicate a transferred challenge on methodology for Ratansara and required MCL to make payments after the High Court’s final order.

The judgment emphasises finality, adherence to the Court’s earlier precise tasking of the Commission, and delineates administrative channels (nodal officers, Collector, statutory tribunals under the Coal Bearing Areas (Acquisition and Development) Act, 1957) for any grievances. Keywords: Compensation claim; Claims Commission; Mahanadi Coalfields; R&R benefits; Gopalpur Model; R&R Act, 2013.

Keywords: Compensation claim; Claims Commission; Mahanadi Coalfields; Rehabilitation & Resettlement benefits; Gopalpur Model.

B) CASE DETAILS

C) INTRODUCTION AND BACKGROUND OF JUDGEMENT

The dispute arises from mass land acquisitions carried out under central authority for coal development in Sundergarh district, Odisha. This Court in SLP(C) No. 6933/2007 appointed a Claims Commission (19.07.2010) to determine compensation for multiple affected villages following the Gopalpur Model. Over time the Commission produced reports for several villages; this Court approved many reports and thereby crystallised entitlements and remedies for those villagers. When the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 came into force, the question surfaced whether its First Schedule benefits apply to acquisitions and awards made at different times.

The Court dissected the temporal applicability holding that the R&R Act applies from 28.08.2015 for this acquisition and directed limited re-determination for four villages whose Commission reports were not approved prior to that date. Subsequent procedural frictions followed: the Claims Commission, while still functioning, entertained numerous matters including re-opening finalized determinations and addressing R&R site suitability and PAF/PDF lists. MCL contested the Commission’s actions, alleging unauthorized re-opening and methodological errors; in at least one aspect (Ratansara) the methodology dispute was transferred to the Orissa High Court.

The present judgment responds to multiple Miscellaneous Applications: an application by the Commission for extension to finalise Ratansara; applications seeking directions to prepare PAF/PDF lists and expedite cases. The Court revisited its prior definitive directions (03.11.2022) and constrained the Commission to the narrow task previously mandated, refused further extension of the Commission’s term, and routed contested methodological questions to the High Court, preserving finality for already-approved village determinations.

D) FACTS OF THE CASE

The central factual matrix: large tracts of land across 14 villages were acquired initially under central authority for coal extraction and development. The Claims Commission was appointed to determine compensation across those villages (list includes Sardega, Jhupurunga, Ratansara, Tikilipara, Siarmal, Tumulia, Karlikachhar, Kulda, Bankibahal, Balinga, Garjanbahal, Bangurkela, Kiripsira, Lalma R.F.). The Commission reported in phases; the Court approved the Gopalpur recommendations (19.04.2012) and subsequently approved reports for several other villages in 2012–2013, adopting the Gopalpur Model.

Two villages (Kiripsara, Ratansara) were noted to have been transferred to successor companies; initial liability lay with MCL with right to recover. By 10.07.2017 the Court disposed of the SLP after receiving Commission reports and Amicus suggestions, leaving open objections to High Court or Commission. On 03.11.2022 this Court issued exhaustive final directions: fixed a common cut-off date (September 2010) for market-value based compensation for certain villages, clarified temporal applicability of the R&R Act, 2013 (applicable from 28.08.2015), and mandated that ten village determinations stand final.

For four villages (Tumulia, Jhupuranga, Ratansara, Kiripsara) a re-determination only to calculate differentials (market value, solatium, interest) under the First Schedule was ordered. The Claims Commission continued to function and, by mid-2024, reported pendency (thousands of civil and misc. cases, certification of resettlement sites, and determination of R&R benefits). MCL objected: Commission purportedly re-opened finalized matters for ten villages, entertained site suitability and PAF/PDF matters beyond its remit, and purportedly adopted an erroneous calculation methodology for Ratansara the latter transferred to Orissa High Court (W.P. (C) No. 39185/2023).

The Commission sought an extension to finalise Ratansara; affected committees sought directions to prepare PAF/PDF lists for the four villages. The Supreme Court was asked to grant extension and further directions; MCL pressed for closure and locus to statutory mechanisms.

E) LEGAL ISSUES RAISED

i. Whether the Claims Commission’s term can be extended to finalise the report for Ratansara beyond dates fixed by this Court?
ii. Whether the Commission can re-open determinations already approved by this Court for ten villages?
iii. Whether the Commission may determine R&R entitlements or prepare PAF/PDF lists for the four remaining villages contrary to the specific narrow re-determination directed?
iv. Whether the Commission may adjudicate suitability of resettlement sites and other implementation matters when this Court has assigned such implementation roles to State authorities and nodal officers?
v. What is the appropriate forum and timeline to adjudicate methodological objections (e.g., Ratansara calculation methodology)?

F) PETITIONER / APPELLANT’S ARGUMENTS

i. The Secretary-cum-Administrative Nodal Officer (Claims Commission) sought extension of time to finalise Ratansara, asserting pending task completion.
ii. Manikeswari Bisthapita Committee/applicants urged that the Commission be directed to prepare PAF/PDF lists and determine R&R benefits for Tumulia, Jhupurunga, Kiripsira, Ratansara as per earlier orders.
iii. Several applicants pressed for expedition and early disposal of individual claims pending before the Commission.

G) RESPONDENT’S ARGUMENTS

i. MCL objected emphatically: the Commission exceeded its mandate by entertaining matters relating to the ten villages already finalized by this Court; reopening those matters violates the explicit bar laid down in paragraph 68(iii)(c) of 03.11.2022.
ii. For the 24 writ petitions and R&R grievances, established statutory mechanisms (District Collector, Odisha R&R Policy 2006/2013, and CBA Tribunal under CBA Act, 1957) are competent; the Commission has no role in preparing PAF lists or allotment.
iii. Methodological objections for Ratansara have already been transferred to the Orissa High Court (W.P. (C) No. 39185/2023); further action on the same before the Commission would be inconsistent.
iv. MCL argued immediate closure, limited scope to calculate only the differential components for the four villages, and that payments ought follow final High Court determination where methodology disputes subsist.

H) JUDGEMENT

The Court refused any further extension of the Commission’s term. It held that the Commission had travelled beyond the narrowly-circumscribed task fixed by the judgment dated 03.11.2022 and had improperly entertained re-opened claims concerning ten villages which had attained finality. The Court reiterated Paragraph 34 of the earlier judgment: for the four villages (Tumulia, Jhupuranga, Ratansara, Kiripsira) only the differential payable after re-determination under the First Schedule to the R&R Act, 2013 namely market value, solatium and further interest was to be calculated.

The Court observed dissent within the Commission on Ratansara methodology; since MCL had challenged the methodology and the matter had been transferred to the Orissa High Court, the High Court was directed to decide W.P. (C) No. 39185/2023 preferably within three months. The Court expressly refrained from expressing any opinion on the correctness of the Commission’s calculations for Ratansara, leaving it to the High Court. The applications seeking directions to prepare PAF/PDF lists or to have the Commission determine wide-ranging R&R benefits were dismissed because the Court’s prior orders had delineated state and administrative mechanisms (Collector, nodal officers) to prepare lists and implement R&R.

The Court directed MCL to pay compensation immediately after the High Court’s final order in Ratansara. All miscellaneous applications (including those filed by committee/applicants) seeking broader directions were dismissed. The judgment emphasises finality of orders approved by the Court, the limited tribunal/commission function post-2015 adjustments, and administrative responsibility for resettlement implementation.

a. RATIO DECIDENDI

The core legal principle: determinations approved by the Supreme Court crystallise and cannot be reopened on account of later policy changes; where the R&R Act, 2013 applies by virtue of temporal operation (28.08.2015 here), the Claims Commission’s reassessment is limited strictly to the differential arising from application of the First Schedule (market value, solatium, further interest). Administrative implementation of resettlement (PAF lists, site suitability, allotments) falls within State machinery and prescribed nodal officers; the Commission has no residual jurisdiction to perform such executive tasks. When a methodology dispute has been transferred to a higher forum (High Court), the Commission must await judicial determination and cannot proceed to final payments inconsistent with that transfer. The Court thus enforced judicial finality and demarcated tribunal/administrative domains.

b. OBITER DICTA

The Court observed (obiter) the proper administrative architecture for R&R implementation: the State must appoint and retain nodal officers for at least three years to coordinate development of plots; the Collector must publicise allotment processes and record disclaimers where families opt for cash alternatives; the State/MCL jointly bear funding obligations to develop facilities in accordance with the Third Schedule to the R&R Act, 2013. The Court reiterated principles of protective measures for SC/ST status under Section 42 of the R&R Act. These observations, while instructive, underscore the executive obligations rather than expand the Commission’s jurisdiction. The Court also noted that practical mechanisms (District Collector, CBA Tribunal) remain available to aggrieved parties for contesting implementation issues.

c. GUIDELINES

i. No extension of the Claims Commission beyond dates fixed by this Court unless strictly necessary and confined to the narrow task ordered.
ii. Commission shall not re-open determinations for villages whose reports were previously approved by this Court.
iii. For villages not approved before 28.08.2015, re-determination is limited to calculating differentials under the First Schedule to the R&R Act, 2013 (market value, solatium, interest).
iv. Methodological disputes that have been transferred to the High Court must be adjudicated by that Court; payments and further action to follow that final adjudication.
v. State to deploy at least three nodal officers, not posted out for at least three years, empowered to coordinate resettlement development and allotment.
vi. District Collector to prepare and publicise PAF/PAF-approval processes — where Collector approves, R&R benefits flow as per approved lists; Commission has neither role to prepare PAF lists nor to allot plots.
vii. Where displaced families disclaim allotment, a one-time cash settlement (as per Court directions) becomes payable, with interest as appropriate.
viii. Aggrieved parties shall approach the High Court for fresh disputes on compensation calculation or disbursement; the Supreme Court will not entertain piecemeal miscellaneous applications after issuing comprehensive directions.

I) CONCLUSION & COMMENTS

The judgment reasserts judicial finality and narrowly construes the role of an adjudicatory Commission when higher courts have already fixed the terms of redetermination. It balances the need for statutory fairness (application of the R&R Act, 2013 where temporally applicable) with administrative practicality (assigning resettlement implementation to State machinery). Practitioners must note the Court’s insistence that where awards have been approved by the Supreme Court, subsequent policy changes cannot be invoked to reopen entitlements. Disputes over calculation methodology must be channelled promptly to the High Court; the Supreme Court expected expeditious adjudication (three months direction for Ratansara).

For litigants and administrators, this ruling underlines:

(i) limited remedial scope once the apex court has approved Commission reports;

(ii) primacy of statutory processes (Collector, CBA Tribunal) for implementation and grievance redressal;

(iii) necessity to seek timely High Court adjudication for any challenge to methodology or computation before execution of payments.

J) REFERENCES

a. Important Cases Referred

i. Mahanadi Coal Fields Ltd. & Anr. v. Mathias Oram & Ors., [2025] 1 S.C.R. 158 : 2025 INSC 22.

b. Important Statutes Referred

i. Coal Bearing Areas (Acquisition and Development) Act, 1957.
ii. Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013.
iii. Orissa R&R Policy, 2006 (as amended 2013).