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Issues Involved:
1. Awardees who received compensation with protest and submitted applications for reference under Section 18 of the Land Acquisition Act after the stipulated time. 2. Awardees who received compensation without protest but submitted applications for reference under Section 18 of the Land Acquisition Act. 3. Awardees who received compensation without protest and did not submit applications under Section 18 of the Land Acquisition Act. 4. The role and rights of the Association representing landowners. 5. The applicability of Section 5 of the Limitation Act, 1963. 6. The right to just compensation and the procedural requirements under the Land Acquisition Act. Issue-wise Detailed Analysis: 1. Awardees who received compensation with protest and submitted applications for reference under Section 18 of the Land Acquisition Act after the stipulated time: The Supreme Court held that the provisions of Section 18(1) of the Act are imperative, requiring landowners to file applications within six weeks from the date of the award if present, or within six months from the date of communication if absent. Applications filed beyond this period render the awards final and unchallengeable. The court emphasized that compliance with the statute of limitation is mandatory, and the Collector cannot make a reference if the application is time-barred. The court cited previous judgments to reinforce that the Collector's power to make a reference is circumscribed by the conditions laid down in Section 18, including the limitation period. 2. Awardees who received compensation without protest but submitted applications for reference under Section 18 of the Land Acquisition Act: The court noted that accepting compensation without protest precludes landowners from filing applications for reference under Section 18. The second proviso to Section 31 of the Act states that acceptance of compensation without protest signifies agreement with the award, thus barring further claims. The court reiterated that a specific and written objection to the award is necessary for a valid reference, and general or vague objections are insufficient. 3. Awardees who received compensation without protest and did not submit applications under Section 18 of the Land Acquisition Act: For those who did not submit applications for reference, the court highlighted that they could still seek enhanced compensation under Section 28A of the Act. This provision allows landowners who did not initially file for reference due to ignorance of their rights to receive just compensation. The court emphasized that the Act must be interpreted holistically, ensuring that landowners are not deprived of their right to fair compensation due to procedural lapses. 4. The role and rights of the Association representing landowners: The court acknowledged that the Association could file a writ application representing its members but could not file applications for reference under Section 18 on their behalf. The Association's role is limited to representing the interests of its members in legal proceedings, but individual landowners must comply with the procedural requirements of the Act. The court emphasized that statutory provisions must be strictly adhered to, and the Association cannot bypass these requirements. 5. The applicability of Section 5 of the Limitation Act, 1963: The court held that Section 5 of the Limitation Act, which allows for the extension of the limitation period in certain cases, does not apply to the Land Acquisition Act. The specific limitation periods prescribed in Section 18(2) of the Act are not subject to extension under the Limitation Act. The court referenced previous judgments to support this interpretation, emphasizing that the Collector acts as a statutory authority and not as a court when making references under Section 18. 6. The right to just compensation and the procedural requirements under the Land Acquisition Act: The court underscored that landowners have a right to receive just compensation, which is a valuable right protected under Article 300A of the Constitution of India. The Act provides a fair procedure for determining compensation, including notice to interested persons, making of an award, and the opportunity for reference. The court emphasized that while procedural requirements must be followed, the substantive right to fair compensation should not be undermined. The court also noted that in exceptional situations, superior courts can exercise their power of judicial review to ensure justice. Conclusion: The Supreme Court allowed the appeal filed by M/s Steel Authority of India Ltd., emphasizing the mandatory nature of procedural requirements under the Land Acquisition Act and the strict interpretation of limitation periods. The court dismissed the appeals filed by the Tamil Nadu Housing Board, holding that the Board, having participated in the proceedings without objection, could not later challenge the validity of the reference. The court awarded costs against the Housing Board, underscoring the importance of adhering to procedural requirements while ensuring just compensation for landowners.
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