KHAZAN SINGH (D) BY LRS. vs UNION OF INDIA

The Supreme Court held that a reference made by a Collector under Section 18 of the Land Acquisition Act, 1894 cannot be dismissed for default due to the absence of the claimant or their counsel. The Court clarified that non-participation does not grant the Civil Court jurisdiction to dismiss the reference, emphasizing that the Civil Court must proceed to determine the objections raised in the reference. The appeal was allowed, overturning the High Court's dismissal of the reference for default.