SC Limits Article 227 Powers: Restores ₹1,000/sq ft Valuation in Nandi Corridor Land Dispute

News Citation : 2026 LN (SC) 434

May 1, 2026 : The Supreme Court has reaffirmed the narrow scope of supervisory jurisdiction under Article 227 of the Constitution, holding that High Courts cannot reappreciate evidence or substitute a plausible view taken by a subordinate court merely because another interpretation is possible.

In Nandi Infrastructure Corridor Enterprises Ltd. v. B. Gurappa Naidu & Ors. (2026 INSC 434), a Bench of Justice Aravind Kumar and Justice N.V. Anjaria set aside the Karnataka High Court’s interference with an Executing Court’s determination of land value and restored the original valuation of ₹1,000 per sq. ft.

The dispute arose from a 2007 compromise decree between Nandi Infrastructure Corridor Enterprises (N.I.C.E.) and landowners, under which N.I.C.E. was obligated to either convey alternative land or pay the “guideline value” of land used for the Bangalore–Mysore Infrastructure Corridor Project. Upon failure to convey land, execution proceedings were initiated.

The Executing Court, relying on the Karnataka Government’s 17 April 2007 notification, fixed the value at ₹1,000 per sq. ft., treating the land as converted urban property within municipal limits. However, the High Court, exercising jurisdiction under Article 227, reduced the valuation to ₹500 per sq. ft. after impleading the State and relying on its interpretation of the notification.

Disapproving this approach, the Supreme Court held that the High Court exceeded its supervisory jurisdiction. It emphasized that Article 227 does not permit the High Court to act as a court of first appeal or reassess factual findings unless there is patent perversity or jurisdictional error.

The Court observed that the Executing Court’s interpretation of the notification was “plausible and reasonable,” and therefore could not be supplanted merely because an alternative interpretation existed. It further criticized the High Court for involving the State in a private dispute and allowing it to reinterpret its own notification, effectively placing the executive in the role of rule-maker, interpreter, and adjudicator simultaneously.

The Bench clarified that such an approach is impermissible, particularly when the lis is exclusively between private parties. It underscored that supervisory jurisdiction is corrective, not appellate, and must be exercised sparingly.

On merits, the Court held that the applicable guideline value was ₹800 per sq. ft. with a 25% enhancement for land abutting a State Highway, correctly resulting in ₹1,000 per sq. ft. It rejected the application of a residual provision that would halve the value for industrial land, noting that the land already fell within a category where a specific rate was prescribed.

Accordingly, the Court allowed the appeal of the decree holders, dismissed the appeal of N.I.C.E., and restored the Executing Court’s order, confirming compensation at ₹1,000 per sq. ft., aggregating to ₹13.72 crore.

The ruling reinforces settled principles that Article 227 cannot be invoked to revisit factual determinations or substitute judicial discretion with an alternative view, and that executive clarification cannot be used to influence adjudication in private disputes.