ARULMIGHU LAKSHMINARASIMHASWAMY TEMPLE vs U O I

The Supreme Court held that in cases of land acquisition under the Land Acquisition Act, 1894, specifically under Sections 4(1), 23(1), 30, and 31, the Land Acquisition Officer must determine the entitlement to compensation and, in case of disputes regarding title, must refer the matter to the appropriate court. The Court found that both the single Judge and the Division Bench erred in their approaches, and thus directed the Land Acquisition Officer to make a reference under Section 30 to resolve the title dispute. The appeal was allowed, and previous orders were set aside.