Land acquisition compensation: additional amount under Section 23(1A) is not payable on solatium, as both are separately computed on market value.

Under Section 23 of the Land Acquisition Act, 1894, the additional amount under Section 23(1A) is calculated at 12% per annum only on the market value determined under Section 23(1), while solatium under Section 23(2) is a separate 30% statutory benefit for compulsory acquisition. The two components are independent and neither can serve as the base for the other. Accordingly, the additional amount is not payable on solatium, and both allowances remain confined to the market value of the acquired land.

---

---

Issues: Whether the additional amount under Section 23(1A) of the Land Acquisition Act, 1894 is payable on the solatium under Section 23(2) of that Act.

Analysis: Section 23(1A) grants 12% per annum only on the market value of the acquired land determined under Section 23(1), while Section 23(2) grants solatium at 30% on that market value in consideration of the compulsory nature of acquisition. The two amounts are distinct statutory benefits and neither is payable on the other. The earlier authorities relied upon were understood to confirm that additional amount and solatium are both computed only with reference to market value, not to each other.

Conclusion: The additional amount under Section 23(1A) is not payable on solatium under Section 23(2) and is confined to the market value under Section 23(1).

Ratio Decidendi: Under Section 23 of the Land Acquisition Act, 1894, additional amount under Section 23(1A) and solatium under Section 23(2) are independently calculated only on the market value determined under Section 23(1), and neither component can be used as the base for the other.

---