K. KAMALA JAMMANNIAVARU (DEAD) BY LRS. vs THE SPECIAL LAND ACQUISITION OFFICER AND VICE VERSA.

The Supreme Court interpreted the Land Acquisition (Amendment) Act, 1984, specifically Section 30(2), which amended Section 23(2) of the Land Acquisition Act, 1894, to increase the solatium from fifteen percent to thirty percent. The Court held that this amendment applies only to awards made after April 30, 1982, and does not retroactively apply to all pending appeals regardless of the award date. Consequently, the appeals for enhancement of compensation were dismissed, affirming that the Parliament intended limited retrospectivity for the amended provisions.