DR. G.H. GRANT vs STATE OF BIHAR

The Supreme Court held that under the Land Acquisition Act, 1894, the Collector has the authority to make references under both Section 18 and Section 30, which serve distinct purposes. The Court clarified that a person not present in the acquisition proceedings can apply for a reference under Section 30 to determine their right to compensation, even if the Collector has apportioned compensation under Section 11. The Court upheld the High Court's decision that the State was entitled to compensation after the land vested in it under the Bihar Land Reforms Act, 1950, thus affirming the State's right to seek a reference under Section 30.