STATE OF KERALA vs GEORGE JOSEPH

The Supreme Court held that under Section 23(1A) of the Land Acquisition Act, 1894, the respondent is not entitled to additional compensation as the award by the Collector was dated March 27, 1981, and the notification under Section 4(1) was issued on September 26, 1978. The Court clarified that the entitlement to additional compensation is contingent upon the timing of the award in relation to the notification. Consequently, the appeals were allowed and the award was set aside to that extent, with no costs awarded.