Interest on land acquisition compensation continues until court deposit, and cheque preparation alone does not end liability.

Interest on land acquisition compensation under the Land Acquisition Act, 1894 continues until the amount is actually paid to the owner or deposited in court. Mere preparation of cheques or keeping the compensation available for collection does not end the statutory liability where the State neither secures collection nor makes a court deposit; retaining and using the money in the revenue account does not avoid interest. Section 53 prevents reliance on a conflicting procedural rule to defeat the Act's express payment scheme. The result is that interest remains payable until deposit in court.

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Issues: Whether interest on compensation under the Land Acquisition Act, 1894 continues to run until the amount is deposited in court, where the State prepared cheques in favour of the claimants but did not deposit the uncollected amount in court and instead retained and utilised it in its revenue account.

Analysis: The liability to pay interest under Sections 28 and 34 of the Land Acquisition Act, 1894 continues until the compensation is paid to the owner or interested person or deposited in court. The principle laid down in Prem Nath Kapur was applied to hold that the liability ceases only on deposit in court. Section 53 excludes the application of Order XXI Rule 1 of the Code of Civil Procedure, 1908 to the extent it is inconsistent with the express scheme of the Act. Mere preparation of cheques or keeping the amount available for collection does not satisfy the statutory requirement when the amount is neither collected nor deposited in court, and the State cannot retain and utilise the money and at the same time avoid interest.

Conclusion: The High Court's view was set aside and the appellants were held entitled to interest as directed by the District Judge.

Final Conclusion: Interest on land acquisition compensation remains payable until the amount is deposited in court, and the State cannot escape liability by retaining uncollected compensation in its own accounts and utilising it.

Ratio Decidendi: Under the Land Acquisition Act, 1894, the statutory liability to pay interest on compensation continues until actual deposit in court, and a conflicting procedural provision cannot displace that mandate.

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