COLLECTOR, CUTTACK vs DURYODHAN JENA

The Supreme Court held that under the Land Acquisition Act, 1894, specifically Sections 23(2), 28, and 23(1A), claimants are not entitled to enhanced benefits if the civil court's award predates the Amendment Act 68 of 1984. The Court ruled that the High Court lacked jurisdiction to award additional benefits since the claimants did not appeal for further enhancement. Consequently, the appeal was allowed, and the High Court's order awarding solatium, interest, and additional amounts was set aside.