Latest JudgementConstitution of India

Nandi Infrastructure Corridor Enterprises Ltd. v. B. Gurappa Naidu, 2026

The Supreme Court held that Article 227 confers only supervisory jurisdiction and not appellate jurisdiction.

Supreme Court of India·2 May 2026
Nandi Infrastructure Corridor Enterprises Ltd. v. B. Gurappa Naidu, 2026
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Judgement Details

Court

Supreme Court of India

Date of Decision

2 May 2026

Judges

Justice Aravind Kumar & Justice N.V. Anjaria

Citation

Acts / Provisions

Article 227 of the Constitution of India

Facts of the Case

  • The dispute arose from a 2007 compromise between Nandi Infrastructure Corridor Enterprises Limited and landowners in Bengaluru regarding land acquisition for a road project.

  • The agreement required either providing alternative land or paying compensation based on government guideline value.

  • The company failed to provide alternative land, leading to execution proceedings.

  • The Executing Court fixed compensation at ₹1,000 per square foot.

  • The High Court reduced compensation to ₹500 per square foot under Article 227.

  • The reduction was challenged before the Supreme Court of India

Issues

  1. Whether the High Court under Article 227 can re-appreciate facts and substitute its own view for that of the subordinate court?

  2. Whether supervisory jurisdiction under Article 227 allows modification of findings on merits?

  3. Whether the High Court exceeded its jurisdiction by altering compensation fixed by the Executing Court?

Judgement

  • The Supreme Court held that Article 227 confers only supervisory jurisdiction and not appellate jurisdiction.

  • The Court held that High Courts cannot re-appreciate evidence or substitute findings on merits.

  • The Court held that interference under Article 227 is permissible only in cases of jurisdictional error, gross abuse of jurisdiction, refusal to exercise jurisdiction, or perversity of findings.

  • The Court observed that the High Court wrongly acted as an appellate court by reassessing compensation.

  • The Court held that there was no jurisdictional error or perversity in the Executing Court’s decision.

  • The Court held that the High Court exceeded its limited supervisory jurisdiction under Article 227

Held

  • The appeal was allowed.

  • The Supreme Court held that Article 227 is strictly supervisory in nature.

  • The Supreme Court held that High Courts cannot act as appellate courts under Article 227.

  • The Supreme Court restored the Executing Court’s compensation of ₹1,000 per square foot.

  • The Supreme Court set aside the High Court’s reduction of compensation.

Analysis

  • The judgment reinforces the limited scope of Article 227 supervisory jurisdiction.

  • The judgment clarifies that High Courts cannot re-appreciate evidence or facts under Article 227.

  • The judgment strengthens the distinction between supervisory jurisdiction and appellate jurisdiction.

  • The judgment prevents High Courts from substituting their own views for subordinate courts.

  • The judgment ensures judicial discipline within the hierarchy of courts.

  • The judgment promotes finality of factual findings by subordinate courts.

  • The judgment prevents misuse of Article 227 for re-litigation on merits.

  • The judgment reinforces judicial restraint and procedural efficiency.