SMT. AMBEY DEVI vs STATE OF BIHAR & ANR.

The Supreme Court held that a co-sharer cannot claim enhancement of compensation under the Land Acquisition Act, 1894 without seeking a reference under Section 18. The Court emphasized that the procedure outlined in the Act is inconsistent with the Civil Procedure Code, and a valid reference is a prerequisite for the civil court to adjudicate on compensation claims. The appeal was dismissed as the appellant failed to file an application under Section 18 after the Collector's award, thus not entitled to enhanced compensation.