The Supreme Court ruled that a Reference Court under the National Highways Act, 1956 can incidentally determine questions of title while deciding compensation entitlement. The court held that such determination is not a final adjudication of title but a necessary incidental inquiry to resolve who is entitled to receive compensation for land acquired under the Act. This ruling clarifies the jurisdictional scope of Reference Courts and protects Article 300A rights of persons whose title is disputed during highway land acquisition proceedings.

This ruling sits at the intersection of Article 300A (right to property) and the National Highways Act, 1956 (NHA). Under the NHA, when the competent authority determines compensation for acquired land, a person aggrieved may seek a reference to a Reference Court under Section 3G(5). The core question was: can the Reference Court go into title disputes, or must it confine itself to quantum of compensation?

The Supreme Court applied the doctrine of incidental jurisdiction — a court seized of a matter may determine ancillary questions necessary to decide the primary issue, even if those questions would otherwise fall outside its jurisdiction. Determining who owns the land is a precondition to determining who receives compensation. Denying the Reference Court this power would create a constitutional lacuna: a person with a valid claim could be deprived of property compensation without any forum to establish entitlement.

The Article 300A dimension is critical: no person shall be deprived of property save by authority of law. The Supreme Court has consistently read this to mean not just that acquisition must be lawful, but that the person must receive fair compensation through a meaningful legal process. Blocking title inquiry at the Reference Court stage would undermine this guarantee.

Note the limitation: this determination of title is incidental and not res judicata — it binds only for compensation purposes, not as a final civil court decree on title. The distinction between incidental determination and final adjudication is the precise conceptual boundary the examiner will test.