UNION OF INDIA AND ANOTHER ETC. ETC. vs ZORA SINGH ETC. ETC.

The Supreme Court held that Section 23(1-A) of the Land Acquisition Act, 1894 confers substantive rights to claim additional compensation for land acquisition, applicable only prospectively unless explicitly stated otherwise. The Court affirmed that the term 'award' in Section 23(1-A) indicates its applicability to cases where the Collector had not yet made an award at the time of the provision's enactment. The Court dismissed the State's appeal, upholding the High Court's decision to grant benefits under Section 23(1-A) to the landowners, confirming their entitlement to additional compensation.