State Of Kerala vs Paily Mani And Ors.

The Supreme Court held that the benefit of Section 23(1-A) of the Land Acquisition (Amendment) Act, 1984 is not applicable to the respondents since the award by the Collector was passed on 5th April, 1980, and the court's decision in K.S. Paripoornan v. State of Kerala establishes that such benefits cannot be claimed if the award predates the amendment. Consequently, the appeals were allowed, modifying the trial court's award to exclude the benefit under Section 23(1-A) while confirming the rest of the award.