Statutory scheme for land acquisition interest bars equitable writ relief beyond Sections 28 and 34 of the 1894 Act.

The SC held that interest on land acquisition compensation must be confined to the statutory scheme under Sections 28 and 34 of the Land Acquisition Act, 1894. Section 34 governs interest where possession is taken before payment, and Section 28 permits interest only on excess compensation awarded by the court. Because the Act is a complete and self-contained code on compensation and interest, Article 226 cannot be used to grant interest on equitable grounds or beyond the statute's rates, period, or manner. The direction granting interest outside the Act was impermissible and was set aside.

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Issues: Whether, in proceedings under Article 226 of the Constitution of India, the Court could direct payment of interest on land acquisition compensation otherwise than in accordance with Sections 28 and 34 of the Land Acquisition Act, 1894.

Analysis: The statutory scheme was treated as exhaustive on the subject of interest. Section 34 governs interest on compensation when possession is taken before payment, and Section 28 permits interest only on excess compensation awarded by the Court. No other provision authorises payment of interest on equitable grounds or in a manner different from the statute. As the Act is a complete and self-contained code on compensation and interest, the writ jurisdiction under Article 226 cannot be used to enlarge the entitlement beyond the statutory rates, manner, and period prescribed by the Act.

Conclusion: The direction to pay interest outside Sections 28 and 34 was impermissible and was set aside in favour of the appellant.

Final Conclusion: The writ court had no power to grant interest on equitable considerations contrary to the statutory scheme governing land acquisition compensation.

Ratio Decidendi: Where a statute provides a complete and self-contained scheme for payment of interest, courts cannot, in writ jurisdiction, award interest on equitable grounds or in a manner not authorised by the statute.

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