Orissa Industrial Infrastructure ... vs Supai Munda & Ors

The Supreme Court held that the provisions of Sections 4(1), 6, 11, and 12(2) of the Land Acquisition Act, 1894 must be adhered to, particularly in ensuring that the rights of landowners, especially illiterate tribal villagers, are protected during the acquisition process. The Court found that the coercion faced by the respondent to accept the compensation without protest violated the principles of natural justice. Consequently, the Court upheld the High Court's order directing the Land Acquisition Officer to refer the matter for higher compensation to the civil court, emphasizing the need for fair hearing and due process in land acquisition matters.