Limitation for land acquisition reference turns on actual knowledge of the award's essential contents, not mere award date.

Under the proviso to Section 18 of the Land Acquisition Act, 1894, the six-month limitation period for seeking a reference does not run merely from the date of the award where the claimant was not present or represented and no notice under Section 12(2) was served. Time begins when the award is actually or constructively communicated or otherwise known, and knowledge must extend to the essential contents of the award. On the evidence, an earlier application for interim payment did not prove such knowledge; the accepted date of knowledge was receipt of compensation. The reference application was therefore within time and not barred by limitation.

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Issues: Whether an application for a reference under Section 18 of the Land Acquisition Act, 1894 was within time when the landowners had not been present at the award, had not been given notice under Section 12(2), and claimed to have acquired knowledge of the award only on payment of compensation.

Analysis: Under the proviso to Section 18, the six-month period in cases where the claimant was not present or represented before the Collector does not begin merely from the formal date of the award. Where no notice under Section 12(2) is served, the limitation runs from the date on which the award is communicated or otherwise known to the claimant, actually or constructively. Knowledge must relate to the essential contents of the award, not merely to the bare fact that some award was made. On the evidence, the earlier application for interim payment did not establish such knowledge, and the accepted date of knowledge was the date on which compensation was received.

Conclusion: The reference application was within time and was not barred by limitation.

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