Karnal Improvement Trust vs Sumitra Devi (Dead) By Lrs. And Ors

The Supreme Court upheld the dismissal of writ petitions challenging the award of solatium under Sections 23(1-A) and 28 of the Land Acquisition Act, 1894, stating that the provisions of Section 30(1) of the Land Acquisition (Amendment) Act, 1984, limit the applicability of additional compensation. The Court clarified that entitlement to additional amounts under Section 23(1-A) is contingent upon the status of acquisition proceedings as of April 30, 1982, and that no enhancement of compensation beyond the Collector's award was applicable. The appeals were dismissed, affirming the High Court's decision.