STATE OF GUJARAT & ORS. vs AMBALAL HAIDERBHAI ETC.

The Supreme Court held that the inquiry under Rule 4 of the Land Acquisition (Companies) Rules, 1963 requires compliance with the principles of natural justice, as established in Suresh Koshy George v. The University of Kerala and A. K. Kraipak v. Union of India. The Court affirmed the Gujarat High Court's decision to set aside the notification under Section 6 of the Land Acquisition Act, 1894, due to the failure to provide landowners a right to be heard during the inquiry process. The Court emphasized that natural justice principles may be implied from the statutory duties involved.