THE STATE OF PUNJAB vs JAGIR SINGH

The Supreme Court held that under the Land Acquisition Act, 1894, specifically Sections 23(1A), 23(2), and 28, the High Court lacks jurisdiction to award additional statutory benefits when confirming the decree of the Reference Court unless there is an enhancement of compensation beyond the Collector's award. The Court reiterated that the power to award additional amounts is contingent upon the prior enhancement of compensation, as established in previous cases such as Union of India vs. Smt. Pratap and State of Maharashtra vs. Maharau Srawan Hatkar. Consequently, the appeals were allowed, affirming the limitations on the High Court's authority in such matters.