Statutory interest on enhanced land compensation survives procedural defects and may be granted even without separate cross-objections.

The Supreme Court declined to interfere with the High Court's factual valuation of acquired land, holding that the market rate fixed on comparable sale evidence and allowance for the larger block size did not call for correction in an Article 136 appeal. It further held that statutory interest on enhanced compensation under the Land Acquisition Act is a substantive entitlement, not dependent on a separate appeal or valid cross-objections by the claimant. The rejection of the cross-objections as time barred did not defeat that entitlement, and interest was awarded for the relevant period until payment.

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Issues: (i) Whether the valuation fixed by the High Court for the acquired land called for interference. (ii) Whether interest on enhanced compensation could be granted in the State appeal notwithstanding the absence of a separate appeal or cross-objections by the claimant and the rejection of the cross-objections as time barred.

Issue (i): Whether the valuation fixed by the High Court for the acquired land called for interference.

Analysis: The acquired land was valued on the basis of comparable sale instances, with suitable allowance made for the larger size of the acquired block. The High Court rejected reliance on the inspection note and assessed the evidence to determine a reduced market rate. In an appeal under Article 136, the Court found no sufficient reason to disturb that factual determination.

Conclusion: The valuation fixed by the High Court at Rs. 1.35 per square yard was not interfered with and this issue was decided against the appellant.

Issue (ii): Whether interest on enhanced compensation could be granted in the State appeal notwithstanding the absence of a separate appeal or cross-objections by the claimant and the rejection of the cross-objections as time barred.

Analysis: Under Sections 23(1), 26, 27, 28 and 34 of the Land Acquisition Act, 1894, compensation and interest serve different functions. The award under Section 26 is the decree-forming part of the compensation determination, while interest under Sections 28 and 34 is a statutory incident flowing from the acquisition itself when the statutory conditions are met. The payment of interest is not dependent on a separate claim or on compliance with procedural hurdles, and procedural limitations cannot defeat the substantive statutory entitlement. The rejection of the cross-objections as time barred did not bar the claimant from seeking interest in the State appeal.

Conclusion: The claimant was entitled to interest from 19 November 1949 to 1 February 1955 and further interest at 6% per annum thereafter until payment; this issue was decided in favour of the appellant.

Final Conclusion: The appeal succeeded only on the question of interest, while the valuation determined by the High Court was left undisturbed; the claimant obtained additional statutory interest, but no interference was made with the market rate fixed for the land.

Ratio Decidendi: Statutory interest payable under the Land Acquisition Act is a substantive entitlement that can be granted at any stage of the proceedings and is not defeated by the absence or dismissal of separate appeal proceedings or cross-objections, because procedural rules cannot override the statutory right.

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