- 1 - HC-KAR NC: 2026:KHC:8592 WP No. 29527 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 11TH DAY OF FEBRUARY, 2026 BEFORE THE HON'BLE MRS. JUSTICE K.S. HEMALEKHA WRIT PETITION NO. 29527 OF 2025 (LA-KIADB) BETWEEN: 1. SMT. DHANALAKSHMI W/O R. PRAKASH REDDY, AGE: 64 YEARS, NO.24, 209, 4TH MAIN, 6A CROSS, PANDURANGA NAGAR, J.P. NAGAR, 7TH PHASE, BANGALORE-560076. 2. SMT. KOMALA W/O SATHISH REDDY P.S.R. AGE: 62 YEARS, NO.385 & 386, 18TH E MAIN ROAD BLOCK, KORAMANGALA 6TH BLOCK, BENGALURU-560095. 3. SMT. BHARATHI W/O GANESH REDDY, AGE: 58 YEARS, 291, BEHIND GANESH TEMPLE, JIGINI HOBLI, HULIMANGALA, BANGALORE-560105. 4. SMT. LAKSHMI W/O LOKESH REDDY, D/O ROJAMMA AGE: 56 YEARS, NO.11, 3RD CROSS, VINAYAKA GREEN LAYOUT, KANNUR, BANGALORE-562149. 5. SMT. KOKILA W/O NAGESH REDDY, MANJANNA E Digitally signed by MANJANNA E Location: HIGH COURT OF KARNATAKA DHARWAD BENCH Date: 2026.02.16 15:36:05 +0530 - 2 - HC-KAR NC: 2026:KHC:8592 WP No. 29527 of 2025 D/O ROJAMMA, AGE: 54 YEARS, NO.03, NEAR ANJENAYA TEMPLE, SUBRAMANI LAYOUT, HULIMANGALA, JIGINI, BANGALORE-560105. 6. SMT. K. HEMA W/O. K. SADASHIVA REDDY, AGE: 43 YEARS, NO.59-60, AIKYA RESIDENCY, 10TH CROSS, VINAYAKA LAYOUT, HULIMANGALA, BANGALORE-560056 NO.644, K.R. GARDEN , 8TH BLOCK, 11TH CROSS ROAD, KORAMANGALA, BENGALURU-560095. 7. SMT. MANJULA D/O LATE NANJAPPA REDDY, AGED ABOUT 68 YEARS, NO.3, MSR MEADOWS, K. NO.5/6, DEVARACHIKKANAHALLI, BANNERGHATTA ROAD, BANGALORE-560076 8 . SRI R. MANJUNATHA REDDY, AGED ABOUT 59 YEARS, S/O RAMA REDDY, R/AT 267, 7TH CROSS, 27TH MAIN, 1ST SECTOR, HSR LAYOUT, BENGALURU-560102. ...PETITIONERS (BY SRI VIVEK SUBBAREDDY, SENIOR COUNSEL FOR SRI SUBBAREDDY K.N., ADVOCATE) AND: 1. STATE OF KARNATAKA REP. BY ITS SECRETARY, DEPARTMENT OF COMMERCE & INDUSTRIES VIDHANA SOUDHA, BENGALURU-560001. - 3 - HC-KAR NC: 2026:KHC:8592 WP No. 29527 of 2025 2. THE KARNATAKA INDUSTRIAL AREA DEVELOPMENT BOARD REP. BY ITS CHIEF EXECUTIVE OFFICER AND EXECUTIVE MEMBER, NO.14/3, 2ND FLOOR, R.P. BUILDING, NRUPATHUNGA ROAD, BENGALURU-560001. 3. THE SPECIAL LAND ACQUISITION OFFICE-1 METRO RAILWAY PROJECT, KARNATAKA INDUSTRIAL AREA DEVELOPMENT BOARD (KIADB) (METRO RAIL WAY PROJECT) 1ST FLOOR, R.P. BUILDING NRUPATHUNGA ROAD, BENGALURU-560001. 4. THE BENGALURU METRO RAIL CORPORATION LTD., HAVING ITS REGISTERED OFFICE AT B.M.T.C. COMPLEX, 3RD FLOOR, KENGAL HANUMANTHAIAH ROAD, SHANTHI NAGAR, BENGALURU-560001 REP. BY ITS MANAGING DIRECTOR. COMPANY INCORPORATED UNDER THE COMPANIES ACT, 1956. 5. SRI ATUL KUMAR S/O K.N. BAGARA, AGE ABOUT 51 YEARS, NO.26/3, SRINIVASA NIVASA, 2ND FLOOR, 4TH CROSS, K.V. LAYOUT, JAYANAGAR, BENGALURU-560011. 6. SRI B. PRASANNAIAH S/O BRAHMASURAIAH, NO.07, 1ST MAIN, KAS OFFICER COLONY, J.P. NAGAR, 4TH STAGE, BENGALURU-560078. 7. SRI K.V. SRINIVAS REDDY S/O VENKATAPPA, NO.398, 1ST FLOOR, 6TH BLOCK, 18TH MAIN, - 4 - HC-KAR NC: 2026:KHC:8592 WP No. 29527 of 2025 KORAMANGALA, BENGALURU-560095. 8. SRI H.S. SURESH S/O LATE SHIVALINGAIAH, NO.25, 1ST MAIN, RAJIV GANDHI NAGAR, DOLLURU COLONY, BENGALURU-560096. ...RESPONDENTS (BY SRI HARISHA A.S., AGA FOR R-1; SRI SHARAN P. SABARAD, ADVOCATE FOR R-2 & R-3; SRI N.N. HARISH, ADVOCATE FOR R-4; SRI UDAYA HOLLA, SENIOR COUNSEL FOR SRI A. CHANDRACHUD, ADVOCATE FOR R-5 & R-6; NOTICES TO R-7 & R-8 ARE SERVED & UNREPRESENTED) THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA, PRAYING TO QUASHING THE IMPUGNED ORDER PASSED BY THE RESPONDENT NO.3 DATED 12.09.2025 BEARING NO.KIADB/METRO-ACQ/115/2025-26 VIDE ANNEXURE-A; ISSUE A WRIT IN THE NATURE OF MANDAMUS DIRECTING THE RESPONDENT NO 3 NOT TO DISBURSE THE COMPENSATION AMOUNT IN PURSUANCE OF THE ORDER VIDE ANNEXURE- A AND TO REFER THE MATTER BEFORE THE REFERENCE COURT FOR DETERMINATION. THIS WRIT PETITION HAVING BEEN HEARD AND RESERVED FOR ORDERS ON 03.12.2025, COMING ON FOR PRONOUNCEMENT THIS DAY, THE COURT MADE THE FOLLOWING: CORAM: HON'BLE MRS JUSTICE K.S. HEMALEKHA - 5 - HC-KAR NC: 2026:KHC:8592 WP No. 29527 of 2025 CAV ORDER The petitioners have approached this Court calling in question the impugned order dated 12.09.2025 passed by the Special Land Acquisition Officer (SLAO), KIADB, under Section 29 (2) of the Karnataka Industrial Areas Development Act, 1966 (‘KIAD Act’ for short) in respect of land bearing Survey No.18/12, Roopena Agrahara Village, Begur Hobli, Bengaluru South Taluk, measuring 241.73 square meters. Brief facts: 2. The petitioners are the legal heirs of late Nanjappa Reddy, who was the owner and cultivator of several properties, including Survey Nos.18/6, 18/7, 18/8, 18/9 and 18/12 in Roopena Agrahara Village, Begur Hobli, Bengaluru South Taluk. These lands were originally notified for acquisition by the BDA for formation of a layout between Hosur road and Sarjapur road under preliminary notification dated 15.12.1984 and final - 6 - HC-KAR NC: 2026:KHC:8592 WP No. 29527 of 2025 notification dated 28.11.1986. The State Government withdrew the acquisition and de-notified Survey Nos.18/8 and 18/12 vide notification dated 26.11.2002. After the death of Nanjappa Reddy in 1988, dispute arose inter se among his legal heirs regarding division of his properties, leading to several litigations in O.S No.1800/1982, O.S. No.136/2000, O.S. No.2825/2003, O.S. No.263/2003 and RFA No.1975/2013. 3. In 2019, the KIADB again initiated acquisition of Survey Nos.18/12 and 18/8 for the Metro Rail project. One of the legal heirs submitted representations to the SLAO explaining the title dispute. Since the SLAO failed to act on the representations, W.P. No.5358/2019 was filed and this Court directed the SLAO to consider the representations and hear all the concerned parties. The petitioners filed objection asserting that Survey Nos.18/8 and 18/12 belonged to late Nanjappa Reddy. Despite this, the SLAO passed an award on 26.11.2019 directing release of compensation to certain respondents. - 7 - HC-KAR NC: 2026:KHC:8592 WP No. 29527 of 2025 4. The petitioners challenged that award in W.P. No.954/2021. Later, the SLAO issued another notice dated 07.08.2025, stating that the petitioners must produce title documents in compliance with the order passed in W.P. No.24731/2024, where this Court had set aside the general award and directed passing of a consent award subject to verification of title and restoration of general award, if rival claims exist. The petitioners appeared, produced documents and sought reference of the matter to a Civil Court due to the title dispute. The SLAO passed the impugned order dated 12.09.2025 under Section 29 (2) of the KIAD Act, adjudicating title and directing disbursement of compensation instead of referring the dispute to the jurisdiction of the civil Court. 5. Learned senior counsel for the petitioners contends that, Survey No.18/12 originally belonged to late Nanjappa Reddy and has been the subject of a long- standing dispute inter se among the parties. The SLAO, - 8 - HC-KAR NC: 2026:KHC:8592 WP No. 29527 of 2025 despite being presented with rival claims, ought to have referred the matter under Section 30 of the Land Acquisition Act, 1894 (‘LA Act, 1894’ for short). It is submitted that the SLAO had no jurisdiction to decide title, especially when complex issues of inheritance and computing claims are pending adjudication before the Civil Courts including RFA No.1975/2013. It is further contended that only 23 guntas were de-notified in 2002 and petitioners’ rights survive in remaining extent. Therefore, SLAO’s conclusion that the petitioners had no subsisting right is erroneous. It is contended that the very premise on which the SLAO has proceeded is fundamentally flawed. It is contended that ‘there is no concept of consent award’ under the KIAD Act, and the expression used in W.P. No.24731/2024 cannot be construed to confer on the SLAO any jurisdiction to decide questions of title. The core submission is that the SLAO had no authority under Section 29(2) of the KIAD Act to adjudicate upon rival and complex claims of ownership and - 9 - HC-KAR NC: 2026:KHC:8592 WP No. 29527 of 2025 that the impugned order amounts to the SLAO acting as a Civil Court in determining questions of title - an exercise strictly reserved for the Land Acquisition Court under Section 30 of the LA Act, 1894. It is further contended that the SLAO has passed the impugned order contrary to the existence of rival claims, despite the express direction in W.P. No.24731/2024 that if rival claims emerge, the general award must be restored. It is a specific case of the petitioners that the extent of 241.73 square meters acquired for the Metro Rail project is part of 23 guntas that were de-notified under the notification dated 26.11.2002. The petitioners assert that this de-notified portion is the very area that continues to remain in the name of original ancestor and therefore, forms part of their undivided family property. 6. Learned senior counsel stresses that a careful reading of the objections filed by the petitioners clearly reveals the contention that the land now being awarded to respondent Nos.5 and 6 forms part of the de-notified 23 - 10 - HC-KAR NC: 2026:KHC:8592 WP No. 29527 of 2025 guntas and that the SLAO had failed to record any finding on this pivotal aspect. The question therefore is whether the extent withdrawn from the acquisition is the same land now acquired by the KIADB and whether such land would ever have been treated as property belonging to respondent No.5. It is argued that the SLAO has completely overlooked this aspect thereby vitiating the award. 7. Learned counsel for respondent Nos.2 and 3- KIADB submits that a conjoint reading of Sections 28 (2), 29 and 30 of the KIAD Act, together with Section 11 of the LA Act, 1894 which corresponds to Section 23 of the Right to Fair Compensation and Transparency in Land Acquisition Act, 2013 (‘Act, 2013’ for short), makes it evident that the SLAO is empowered to determine prima facie entitlement and decide whether a genuine rival claims exist. It is argued that not every objections or competing assertions must automatically be referred to the Civil Court under Section 30 of the LA Act, 1894, the - 11 - HC-KAR NC: 2026:KHC:8592 WP No. 29527 of 2025 statutory scheme contemplates that only such disputes which involve complicated questions of title warrant interference. Learned counsel submits that the material on record demonstrates that the de-notified portion pertains to the land purchased by the petitioners, and not the land acquired by the KIADB for Metro Rail project. The land acquired by the KIADB had already been subjected to objections long back and those objections were considered, adjudicated and now cannot be reopened or erased merely because of an inter-family dispute. Drawing the attention specifically to paragraph No.27 of the objection learned counsel asserts that the SLAO has correctly recorded that the acquired portion of 241.73 square meters lies within the BDA-acquired and BDA- allotted area, and bears no correlation with the 23 guntas that were withdrawn under Annexure - R3. 8. Learned senior counsel for respondent Nos.5 and 6 submits that the dispute raised by the petitioners is purely an inter se family dispute among the heirs of late - 12 - HC-KAR NC: 2026:KHC:8592 WP No. 29527 of 2025 Nanjappa Reddy, and respondents Nos.5 and 6 are strangers to those disputes. They stress that all the petitioners’ suits as well as RFA pertain to different extents of Survey No.18/12 and do not disturb the BDA allotment or KIADB acquisition. Learned senior counsel places reliance on Annexure - R3, which clearly shows that out of Survey No.18/12, measuring 1 acre 34 guntas, only 23 guntas were de-notified, and remaining 1 acre 11 guntas continued with the BDA. It is submitted that BDA thereafter allotted 2.398 guntas (corresponding to 241.73 square meters) to Karnataka Income Tax Departmental House Building Cooperative Society from whom respondent Nos.5 and 6 derived their title through registered transactions. Reference is made to serial number 7 and 8 of the synopsis, which show that allotment to the society and subsequent sale in favour of respondent Nos.5 and 6. Learned senior counsel asserts that at no point, did the petitioners file any objections to the acquisition or allotment in favour of respondent Nos.5 - 13 - HC-KAR NC: 2026:KHC:8592 WP No. 29527 of 2025 and 6, nor did they challenge the final notification of BDA's title. Hence, the petitioners cannot now contest the allotment or compensation. 9. Learned counsel for respondent Nos.2 and 3 places reliance on the following judgments: i. Mujahid B. Makki and others Vs. The State of Karnataka and others1 (Mujahid B. Makki) ii. S. Venkatashamappa Vs. State of Karnataka and others2 (S. Venkatashamappa) iii. Afzal Bee Vs. The Special Deputy Collector and others3 (Afzal Bee) iv. N. Somashekar and others Vs. State of Karnataka and others4 (N. Somashekar) v. State of Uttar Pradesh and others and others Vs. Kashi Prasad Dwivedi and others5 (Kashi Prasad) 1 W.P. No.15300/2020 D.D. 12.12.2023 2 ILR 2003 KAR 4496 3 AIR 1978 AP 463 4 (1997) 7 Kant LJ 410 - 14 - HC-KAR NC: 2026:KHC:8592 WP No. 29527 of 2025 10. Having heard the learned counsel on both sides, the point that arises for consideration is: “Whether the petitioners have made out any ground to interfere with the impugned order dated 12.09.2025 passed by the Special Land Acquisition Officer under Section 29(2) of the KIAD Act, and whether the SLAO was required to mandatorily refer the rival claims to the jurisdictional Civil Court under Section 30 of the LA Act?” 11. The SLAO by the impugned order held that the petitioners have not challenged the acquisition notification. Even if they succeed in the partition suit, they would be entitled only to the BDA compensation already deposited not to the compensation payable under the KIAD Act. Further, it held that the documents submitted by the claimants establish purchase of 2.398 guntas, including chain of title from BDA allotment to Karnataka Income Tax Departmental House Building Co-Operative Society and the sale deed in favour of claimant Nos.1 and 2. The SLAO 5 (2007) 15 SCC 205 - 15 - HC-KAR NC: 2026:KHC:8592 WP No. 29527 of 2025 has concluded that the title stands established in favour of claimant No.2 and that the objectors’ claim arising out of the partition and declaration suit does not affect the acquisition proceedings. Accordingly, the SLAO has ordered that the compensation under Section 28(2) of the KIAD Act in respect of Survey No.18/12, measuring 241.73 square meters, be paid in favour of claimant No.2, Sri Atul Kumar. 12. The material on record demonstrates that the land bearing Survey No.18/12 Roopena Agrahara Village, measuring 1 acre 34 guntas were notified for acquisition under the final notification dated 29.11.1986. Possession was taken on 23.04.1988. A general award was passed and compensation was deposited before the Civil Court. The petitioners have never challenged these proceedings. The petitioners contend that the extent of 241.73 square meters now acquired by the KIADB constitute a portion of 23 guntas that was de-notified by the State Government in 2002 and therefore, continues to remain part of the - 16 - HC-KAR NC: 2026:KHC:8592 WP No. 29527 of 2025 ancestral estate of late Nanjappa Reddy. It is urged that, if the de-notified portion vested back in the family, the SLAO could not have treated that the said extent belongs to respondent Nos.5 and 6. The petitioners submit that the SLAO failed to appreciate this aspect and mechanically proceeded to accept the title of respondent Nos.5 and 6 without correlating the acquired portion to the de-notified land or conducting an independent verification of the properties. 13. On careful consideration of the rival submissions, this contention cannot be accepted, as the petitioners have failed to produce any material showing that extent of 241.73 square meters is included within the boundaries of de-notified 23 guntas. 14. Section 28(2) of the KIAD Act obligates the Special Land Acquisition Officer to consider objections raised by the persons interested in the land. Section 29 empowers the SLAO to determine the amount of - 17 - HC-KAR NC: 2026:KHC:8592 WP No. 29527 of 2025 compensation and the person to whom such compensation is payable, while Section 30 contemplates a reference to a Civil Court only when the SLAO finds himself unable to decide the dispute regarding apportionment of entitlement. 15. Sections 11 (1) and 11 (3) of the LA Act, 1894 is akin to Section 23 of the Act, 2013, which envisages an administrative determination of compensation and entitlement at the first instance. 16. A conjoint reading of these provisions makes it clear that the statutory scheme does not mandate an automatic reference to the Civil Court upon every objections or rival claim. The duty cast upon the SLAO is to first examine whether the claim raised is genuine, substantial and supported by material or whether it is merely an assertion arising of collateral or inter se disputes. Only when the question of entitlement involves complicated or intractable issues of title, incapable of - 18 - HC-KAR NC: 2026:KHC:8592 WP No. 29527 of 2025 prima facie determination on record, thus Section 30 gets attracted. 17. In the present case, the objections raised by the petitioners are founded primarily on intra family disputes among the legal heirs of late Nanjappa Reddy. The petitioners have not challenged the acquisition notification, the vesting of land or the BDA's allotment proceedings. The record unmistakably shows that only 23 guntas in Survey No.18/12 stood de-notified, while remaining extent continued to vest with the BDA from which 2.398 guntas (241.73 square meters) was subsequently allotted and conveyed through registered documents. The petitioners have failed to place any cogent material demonstrating that the acquired extent of 241.73 square meters forms part of the de-notified land. Their assertion remains unsupported by boundary descriptions, survey sketch, or revenue records. In contrast, the SLAO has relied upon the acquisition records. The surveyor’s report, BDA's allotment, documents and registered - 19 - HC-KAR NC: 2026:KHC:8592 WP No. 29527 of 2025 conveyances, which collectively establish a clear prima facie chain of title in favour of respondents Nos.5 and 6. 18. In Afzal Bee’s case, at paragraph No.6, it is held as under: “6. If Sections 11, 29, 30 and 18 are read together, it becomes obvious that the Land Acquisition Officer has the jurisdiction to apportion the compensation among the persons interested while making an award. That necessarily means that he has the jurisdiction to decide questions of title if such questions are raised before him. But instead of deciding the question of title himself, he has the option to refer such questions to the Court under Section 30 of the Act. Naturally, where complicated questions of title arise, the Land Acquisition Officer will be expected to refer the questions for the decision of the Court under Section 30. But where the questions raised are simple, the Land Acquisition Officer may himself deal with them and incorporate his decision in the award. If he does so and if a party is aggrieved by the apportionment of compensation, such party may seek a reference under Section 18 of the Act. In the present case, the Land Acquisition Officer on the basis of the revenue records came to the - 20 - HC-KAR NC: 2026:KHC:8592 WP No. 29527 of 2025 conclusion that the petitioner was not entitled to any share in certain survey Nos. He issued notice but the petitioner did not choose to adduce any evidence in support of her claim in regard to her share in those survey numbers. The entire amount of compensation in regard to those survey numbers was awarded to respondents 2, 3 and 4. It does not appear that the Land Acquisition Officer has exceeded his jurisdiction in making such award.” 19. The said decision was placed reliance by this Court in S. Venkatashamappa’s case, wherein at paragraph No.9, it is held as under: “9. Thus, by a conjoined reading of Section 29 of the Development Act and Section 11 of the Act, the Deputy Commissioner has to hold an enquiry regarding the entitlement of a person to claim and receive compensation. In the process of conducting an enquiry regarding the entitlement as held by the decision of the Andhra Pradesh High Court by Justice Chinnappa Reddy, as he then was, cited by the learned Counsel for the contesting respondent in Afzal Bee vs. Spl. Deputy Collector and others (supra), the Land Acquisition Officer has jurisdiction to decide even the question of title if it is raised before him. But, if he feels that the ‘question of title’ is a complicated one, he may refer - 21 - HC-KAR NC: 2026:KHC:8592 WP No. 29527 of 2025 the matter to a Civil Court. The process of deciding the claim of the claimant necessarily carries with if the obligation of applying his mind to the material produced or available on record in a fair manner, fairness means that if the land Acquisition Officer wants to use any adverse material or document adverse to the interest of claimant, it can only be done after drawing the attention of the claimant to the adverse material and soliciting his comments or objections, etc. By not doing so, he would be violating the elementary principles of natural justice. Similarly, while conducting the enquiry as stated above, the Land Acquisition Officer will be performing statutory functions and therefore, has to independently take a decision on the basis of records available before him and cannot act on the dictates of any authority however superior he may be.” 20. Further, the Co-ordinate Bench of this Court, while dealing with a similar issue in the case of Mujahaid B. Makki stated supra, and taking into consideration the referred judgments, has held at paragraph No.29 as under: - 22 - HC-KAR NC: 2026:KHC:8592 WP No. 29527 of 2025 “29. As the Apex Court has settled the legal proposition that the land acquisition officer has jurisdiction to look into the issues pertaining to title barring complicated issues of title, perusal of the impugned award reveal that the respondent No.6- SLAO apart from taking note of orders, judgment and decree passed in O.S.No.5220/1992, RFA No.670/2005, W.P.Nos.7797- 98/2019 and also taking note of the deeds of sale, revenue records furnished by private respondents has come to the conclusion that the private respondents had established their right over the properties purchased by them. The narration of facts and reasons assigned by the respondent 6-SLAO in the impugned awards cannot be said to be the one without application of mind. There is indeed reference to the details of the objections raised by the petitioners and determination of the same.” 21. From the referred judgments above, the law laid down is that the statutory scheme under the LA Act, 1894 and the KIAD Act contemplates that the SLAO is the primary authority to consider objections, assess compensation and determine prima facie entitlement to compensation. The SLAO does not act as a mere - 23 - HC-KAR NC: 2026:KHC:8592 WP No. 29527 of 2025 forwarding authority but is required to apply its mind to the material on record and arrive at a reasoned conclusion. 22. The Courts have consistently held that every rival claim or objection does not mandatorily require a reference to the Civil Court under Section 30. A reference is warranted only when dispute involves complicated or intricate questions of title which cannot be resolved on basis of the documents available before the SLAO. Where the questions of entitlement is simple, based on registered documents, revenue records, acquisition records or allotment proceedings, the SLAO himself decide the issue and incorporates such findings in the award. Only where a title dispute is complex requiring detailed evidence and adjudication, thus the duty to refer arise. 23. The law requires that the objection raised under Section 28 (2) must be substantive, specific and supported by cogent material. Mere assertion, vague claims or - 24 - HC-KAR NC: 2026:KHC:8592 WP No. 29527 of 2025 disputes arising out of collateral or intra family litigation without linkage to the acquired land, do not compel a reference. Failure to do with insubstantial objections does not vitiate the award. 24. Section 11 of the LA Act, 1894 and Section 23 of Act 2013 recognize that the award is, at the first instance, an administrative determination. An aggrieved party is not left remediless while dissatisfied with apportionment of entitlement such party may seek a reference under Section 18 or Section 30, as the case may be. The SLAO does not usurp the jurisdiction of the Civil Court merely by determining entitlement under Section 29. Such determination is incidental and statutory in nature and cannot be equated with final adjudication of title inter se parties. 25. The law being well settled that the Land Acquisition Officer is competent to decide prima facie entitlement under Section 29 of the KIAD Act and a - 25 - HC-KAR NC: 2026:KHC:8592 WP No. 29527 of 2025 reference under Section 30 is warranted only where dispute involves complicated questions of title. Mere rival assertion of pending civil disputes do not make a reference. 26. In such circumstances and from the facts narrated above and the petitioners having failed to produce any cogent material demonstrating that the acquired extent 241.73 square meters forms part of the de-notified land, their assertion remains unsupported. The SLAO has relied upon the acquisition records in the surveyor's report, BDA allotment documents and registered conveyance, which collectively establish a prima facie chain of title in favour of respondent Nos.5 and 6. The SLAO, cannot be said to usurped the jurisdiction of a Civil Court. The exercise undertaken by the SLAO is squarely within the corners of Section 29, namely to assess objections, scrutinize competing claims and decide entitlement, where the dispute is not complex. - 26 - HC-KAR NC: 2026:KHC:8592 WP No. 29527 of 2025 27. The petitioners’ contention that rival claim must necessarily be referred to under Section 30, if accepted would render Section 29 otiose, and defeat the legislative intent of administrative scrutiny at the stage of acquisition. Accordingly, this Court finds that the SLAO has acted within the authority conferred under Sections 28 (2), 29 and 30 of the KIAD Act, read with Section 11 of the LA Act, 1894 and equivalent to under Section 23 of the Act, 2013. The objection raised by the petitioners does not disclose a genuine rival claim warranting reference to the Civil Court and accordingly, the point framed for consideration is answered and finding of entitlement recorded in the impugned order is based on material evidence and does not warrant any interference. Accordingly, this Court pass the following: - 27 - HC-KAR NC: 2026:KHC:8592 WP No. 29527 of 2025 ORDER The writ petition is dismissed as devoid of merits. Sd/- JUSTICE K.S. HEMALEKHA MBM CT-RM List No.: 19 Sl No.: 2