LAND ACQUISITION OFFICER, PUNJAB vs ANUDEEP KAUR .

The Supreme Court ruled that Section 23(1-A) of the Land Acquisition Act, 1894, as amended by Act 68 of 1984, does not apply to awards made prior to its enactment, specifically in this case dated July 30, 1981. Consequently, the Civil Court lacks jurisdiction to amend the award to include additional compensation under this section. The Court overturned the High Court's dismissal of the civil revision, allowing the appeals accordingly without costs.