Madan & Anr vs State Of Maharashtra

The Supreme Court held that the High Court erred in declaring the Reference under Section 18 of the Land Acquisition Act, 1894 as time-barred. The Court established that the limitation period for seeking enhancement of compensation begins only after the claimant receives notice of the award under Section 12(2) of the Act, which was not served in this case. Consequently, the Court reversed the High Court's decision and upheld the enhanced compensation awarded by the Reference Court.