Land acquisition compensation: interest is confined to principal compensation, not solatium or the additional statutory amount.

Under the Land Acquisition Act, interest runs only on compensation or enhanced compensation until payment or deposit into court; it does not attach to solatium or the additional amount under Section 23(1-A). The scheme treats compensation, solatium, the additional statutory amount, and interest as separate components, so general appropriation principles under the Code of Civil Procedure cannot be used to apply deposits first to costs and interest before principal compensation. The SC also noted that the High Court had exceeded jurisdiction in granting enhanced statutory benefits beyond the statutory scheme and the applicable stage of enhancement.

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Issues: (i) Whether the amount deposited under the Land Acquisition Act could be appropriated first towards costs and interest before principal compensation; (ii) whether interest under the Act is payable on solatium and the additional amount under Section 23(1-A); (iii) whether the enhanced statutory benefits granted by the High Court were within jurisdiction.

Issue (i): Whether the amount deposited under the Land Acquisition Act could be appropriated first towards costs and interest before principal compensation.

Analysis: The scheme of the Land Acquisition Act treats compensation, solatium, additional amount, and interest as distinct components. Interest under Sections 34 and 28 runs on the compensation or enhanced compensation until payment or deposit into court. Section 53 excludes inconsistent application of Order 21 Rule 1 of the Code of Civil Procedure, 1908. The creditor therefore cannot, by invoking general appropriation principles, apply the statutory deposit first to costs and interest and then claim further interest on the balance.

Conclusion: The claimant was not entitled to appropriate the deposit first towards costs and interest in the manner claimed.

Issue (ii): Whether interest under the Act is payable on solatium and the additional amount under Section 23(1-A).

Analysis: Interest under Sections 34 and 28 is confined to compensation and enhanced compensation under Section 23(1). Solatium under Section 23(2) is an amount in addition to market value, and the additional amount under Section 23(1-A) is a separate statutory benefit. Neither component attracts statutory interest under the Act.

Conclusion: No interest is payable on solatium or on the additional amount under Section 23(1-A).

Issue (iii): Whether the enhanced statutory benefits granted by the High Court were within jurisdiction.

Analysis: The power to award solatium, additional amount, and interest under the amended provisions arises only in accordance with the statutory scheme and the stage of enhancement of compensation. The High Court had exceeded jurisdiction in granting those benefits in the manner it did, and the later amendment could not be applied retrospectively to the revised compensation order in the facts of the case.

Conclusion: The High Court's grant of additional benefits and enhanced solatium and interest was not sustainable.

Final Conclusion: The appeals failed, and the execution was to proceed in accordance with the legal position declared that statutory compensation components are separate and that interest is confined to the principal compensation or enhanced compensation until payment or deposit.

Ratio Decidendi: Under the Land Acquisition Act, interest is payable only on compensation or enhanced compensation until payment or deposit into court, while solatium and the additional amount are separate statutory components that do not themselves carry interest; inconsistent appropriation principles under the Code of Civil Procedure do not override the Act.

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