Section 30 land acquisition references can survive the award and cover post-award entitlement disputes over compensation.

Section 30 of the Land Acquisition Act, 1894 may still be used to refer disputes on apportionment or entitlement to compensation even after the Collector has made and filed the award under sections 11 and 12. The award is conclusive only as between the Collector and persons interested, and does not finally resolve rival claims to the compensation money. The Court also recognised that a post-award devolution of title can sustain a section 30 reference, because the award only quantifies compensation and does not create the right to receive it. A claimant whose title devolves after the award may therefore be covered by the reference.

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Issues: (i) Whether, after making and filing an award under section 11 and section 12 of the Land Acquisition Act, 1894, the Collector can still refer a dispute on apportionment or entitlement to compensation to the Court under section 30. (ii) Whether a person whose title to the acquired land devolves after the award can raise or sustain a reference under section 30 as to the person entitled to receive compensation.

Issue (i): Whether, after making and filing an award under section 11 and section 12 of the Land Acquisition Act, 1894, the Collector can still refer a dispute on apportionment or entitlement to compensation to the Court under section 30.

Analysis: The scheme of the Act distinguishes between the Collector's statutory duty to make an award on area, compensation, and apportionment, and the power to refer disputes to the Court. Section 30 is not confined to a stage before the award is made, and it does not depend on the Collector having left apportionment undecided in the award. The award is conclusive only between the Collector and the persons interested, and it does not finally determine conflicting claims among claimants to the compensation money. A dispute as to the person entitled to receive compensation, or as to apportionment, may therefore still be referred under section 30.

Conclusion: The Collector can make a reference under section 30 even after making and filing the award.

Issue (ii): Whether a person whose title to the acquired land devolves after the award can raise or sustain a reference under section 30 as to the person entitled to receive compensation.

Analysis: The right to compensation is not created by the award; the award only quantifies the amount payable. Where title to the land has statutorily vested in another person after the award, the dispute as to who is entitled to the compensation money is a dispute within section 30. The statutory power is broad enough to cover claims arising after the award, and nothing in the Act limits section 30 to persons whose rights existed on the date of the award. A claimant who acquires title after the award may therefore be the subject of, and may sustain, a reference on entitlement to compensation.

Conclusion: Yes. A person whose title devolves after the award can be the basis of a valid reference under section 30.

Final Conclusion: The appeals fail because the reference under section 30 was competent and the State's claim to the compensation money could be adjudicated in that reference.

Ratio Decidendi: A reference under section 30 of the Land Acquisition Act, 1894 is not barred by the making and filing of the award under section 11 and section 12, and it may validly encompass disputes as to who became entitled to the compensation by reason of a post-award devolution of title.

Dissenting Opinion: Subba Rao, J. took the view that once the Collector has made and filed an award apportioning compensation under section 11 and section 12, he cannot thereafter reopen apportionment by making a reference under section 30, because the award becomes final and can be questioned only by the procedure prescribed for references under section 18.

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