Pralhad & Ors vs State Of Maharashtra & Anr

The Supreme Court addressed the applicability of Section 23(1A) of the Land Acquisition Act, 1894, in the context of pending proceedings. The Court held that additional benefits under this section cannot be granted in the absence of an appeal or cross-objection from the claimants, affirming the High Court's dismissal of the landowners' application under Order 41, Rule 33 of the CPC. The ruling clarified that the amendment benefits are contingent upon proper procedural adherence, thus upholding the Reference Court's award without further enhancement.