Limitation for land acquisition references starts on communication of the award, not mere signing or filing.

Limitation for seeking a reference under the proviso to Section 18 of the Land Acquisition Act, 1894, runs from the date the award is communicated to, or otherwise becomes known by, the person interested, not merely from the date the Collector signs or files it. The award is treated as substantively operative only when it is made known to the affected owner, and Section 12(2) supports that reading by requiring notice to persons not present when the award is made. A contrary literal approach would defeat the right to seek a reference where no notice is given. On that basis, the reference application was held within time.

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Issues: Whether the period of limitation under the proviso to Section 18 of the Land Acquisition Act, 1894, for seeking a reference to court runs from the date when the Collector signs or files the award, or from the date when the award is communicated to, or otherwise becomes known by, the person interested.

Analysis: The award under the Act is not treated as a merely internal administrative act; it operates in substance as an offer or tender of compensation to the owner. On that footing, the making of the award cannot be divorced from communication to the affected person, because a person cannot be expected to act on a decision that has not been made known to him. Section 12(2) itself requires immediate notice of the award to persons not present when it is made, which supports the view that the award becomes effective for limitation purposes only when it is communicated or is otherwise within the actual or constructive knowledge of the claimant. A literal computation of six months from the date of signing or filing would defeat the statutory right to seek a reference where no notice is given.

Conclusion: The limitation period under the proviso to Section 18 begins only when the award is communicated to, or is known by, the person interested, and not merely from the date on which the Collector signs or files it. The application for reference was therefore within time and the appellant succeeded.

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