Solatium forms part of compensation under land acquisition law, so interest applies to the full awarded amount.

Solatium under Section 23(2) of the Land Acquisition Act, 1894 was treated as a statutory component of compensation, alongside market value and other elements under Section 23. Because Sections 28 and 34 require interest on delayed payment of compensation, and Section 31(1) obliges payment of the full awarded compensation, interest extends to the aggregate compensation including solatium unless the statute expressly excludes that component. Section 24 was read as excluding only the specified matters and not solatium, which is granted for the compulsory nature of acquisition.

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Issues: Whether solatium payable under Section 23(2) of the Land Acquisition Act, 1894 forms part of the compensation on which interest is payable under Sections 28 and 34 of the Act.

Analysis: The compensation scheme under the Act was examined as a whole. Section 23 contains the components of compensation, including market value, additional amount, and solatium. Sections 28 and 34 require payment of interest on the compensation awarded when payment is delayed. Section 31(1) obliges payment of the compensation awarded, which necessarily includes all statutory components of compensation. Section 24 excludes certain matters from compensation, but that exclusion does not cover solatium, which is separately granted in consideration of the compulsory nature of acquisition. The distinction between damage for disinclination to part with land and solatium was emphasized, and the aggregate amount under Section 23 was held to be the amount on which interest accrues.

Conclusion: Solatium under Section 23(2) is part of the compensation award, and interest is payable on the aggregate compensation including solatium under Sections 28 and 34.

Ratio Decidendi: Where solatium is a statutory component of compensation under the land acquisition law, interest payable on delayed compensation extends to the entire awarded compensation unless the statute expressly excludes that component.

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