VidhiSangh

Supreme Court of India · 06/02/2026

STATE OF WEST BENGAL & ORS. versus JAI HIND PVT. LTD.

[2026] 2 S.C.R. 497 · 2026 INSC 132

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Summary

In 2008, on a State Government direction following a settlement proposal, a Revenue Officer reviewed a 1971 order under the West Bengal Estates Acquisition Act that had vested a company's agricultural land in the State; the High Court upheld the review. The Supreme Court held that the review was without jurisdiction and void: a quasi-judicial authority has no review power unless the statute expressly confers it, and Section 57A's grant of civil court powers does not include review. The review also failed on the Order XLVII Rule 1 grounds, and the 1971 vesting order was restored.

Issues

  1. Whether a Revenue Officer under the WBEA Act, 1953, invested with all powers of a civil court under Section 57A, could review a concluded 1971 vesting order on a Government direction.
  2. Whether the company proved that it was engaged exclusively in farming on 01.01.1952 so as to retain land under Section 6(1)(j).
  3. Whether, even if a review power existed, any ground for review was made out.
  4. Whether the alleged amicable settlement, promissory estoppel, non-payment of compensation or continued possession assisted the company.

Provisions considered

Held

Result

Appeal allowed; High Court judgment dated 17.05.2012 set aside; the Tribunal's order dated 31.03.2010 restored and the review order dated 07.05.2008 quashed; the vesting order dated 07.10.1971 to continue to operate in accordance with law.

Judgment PDF: Supreme Court of India, [2026] 2 S.C.R. 497.