STATE OF PUNJAB vs SADHU RAM

The Supreme Court held that under Section 16 of the Land Acquisition Act, 1894, the right, title, and interest of the erstwhile owner extinguished upon the passing of the award, making the Government the absolute owner of the property. The Court found that the respondent's claim to equitable ownership was unfounded as he had not followed the legal procedure for denotification under Section 48(1) of the Act. Consequently, the Court reversed the High Court's decree and upheld the trial and appellate courts' decisions, denying the respondent's claim to the land.