KARNAL IMPROVEMENT TRUST vs SUMITRA DEVI (DEAD)BY LRS. .

The Supreme Court upheld the dismissal of writ petitions challenging the award of solatium at 30% of market value under Sections 23(1-A) and 28 of the Land Acquisition Act, 1894. The Court clarified that the provisions of Section 30(1) of the Land Acquisition (Amendment) Act, 1984, limit the applicability of additional amounts under Section 23(1-A) to cases pending as of April 30, 1982, or commenced thereafter, and emphasized that if no enhancement of compensation was made beyond the Collector's award, benefits under Section 28 are also not applicable. The judgment of the Punjab and Haryana High Court was affirmed, maintaining the legal interpretation established in prior cases such as Union of India v. Filip Tiago De Gama and Kashiben Bhikabai v. Special Land Acquisition Officer.