Land acquisition timing rule under the amended Act: Section 6 declaration must follow Section 4(1) notification, not be published the same day.

After the 1984 amendment to the Land Acquisition Act, a declaration under Section 6 could be made only after the date of publication of the preliminary notification under Section 4(1). The Court applied the plain meaning of the amended wording in Section 17(4) and treated the temporal sequence as deliberate, so simultaneous publication of the Section 4(1) notification and Section 6 declaration was impermissible even where urgency provisions were invoked and Section 5-A was dispensed with. The earlier pre-amendment authority allowing same-day publication was distinguished. The same-day declaration was therefore invalid, and the acquisition could not proceed on that basis.

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Issues: Whether, after the 1984 amendment to the Land Acquisition Act, 1894, a declaration under Section 6 could be made and published on the same date as the preliminary notification under Section 4(1) when the urgency provisions had been invoked and Section 5-A was dispensed with.

Analysis: The amended language of Section 17(4) authorises a declaration under Section 6 only after the date of publication of the notification under Section 4(1). The change in wording was treated as deliberate and not merely verbal. Reading the provision according to its plain meaning, the Court held that the expression "after the date" requires a temporal sequence between the two steps. The scheme of the Act after amendment did not justify treating the words as otiose. Earlier authority permitting simultaneous publication before the amendment was distinguished on the footing that the statutory language had since changed.

Conclusion: Simultaneous publication of the Section 4(1) notification and the Section 6 declaration was not permissible under the amended Act, and the impugned declaration was invalid.

Final Conclusion: The acquisition could not proceed on the basis of the same-day Section 4 and Section 6 publications, and the challenge to the acquisition notifications succeeded.

Ratio Decidendi: Where the statute, as amended, requires a declaration to be made only after the date of publication of the preliminary notification, the declaration must follow the preliminary notification in point of time and cannot be published simultaneously with it.

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