Beneficial interpretation of land acquisition compensation rules extends redetermination rights and permits interest on additional compensation.

Section 28-A of the Land Acquisition Act is a beneficial redetermination provision, so the three-month limitation runs from any qualifying award made after the provision came into force and not only from the first such award; reading a "first award" restriction into the text would improperly narrow the statutory benefit. The Collector, when redetermining compensation under Section 28-A(2), may also grant interest on the additional amount because that award determines compensation payable to the applicant and attracts Section 34. The provision is intended to remove inequality between similarly placed landowners who did not seek a Section 18 reference.

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Issues: (i) Whether the three-month period for moving an application under Section 28-A of the Land Acquisition Act, 1894 runs only from the first award made after the coming into force of Section 28-A, or from any award under Part III made after that provision became operative. (ii) Whether the Collector, while redetermining compensation under Section 28-A, can award interest on the additional amount of compensation.

Issue (i): Whether the three-month period for moving an application under Section 28-A of the Land Acquisition Act, 1894 runs only from the first award made after the coming into force of Section 28-A, or from any award under Part III made after that provision became operative.

Analysis: Section 28-A confers a remedial right on persons whose land is covered by the same notification under Section 4(1) but who did not seek reference under Section 18. The provision is beneficial in character and is intended to remove inequality in compensation by enabling similarly placed landowners to seek redetermination when any one of them obtains a higher award from the court. Reading the word "first" into Section 28-A would restrict the statutory benefit by judicial addition of words not found in the text and would defeat the legislative object. The limitation period therefore runs from the date of the award on which redetermination is sought, provided that award is one made after Section 28-A came into force and the other statutory conditions are satisfied.

Conclusion: The right under Section 28-A is not confined to the first award after the amendment; an application may be founded on any qualifying award made after Section 28-A came into force, if filed within three months from that award.

Issue (ii): Whether the Collector, while redetermining compensation under Section 28-A of the Land Acquisition Act, 1894, can award interest on the additional amount of compensation.

Analysis: Although Section 28 empowers the court to award interest on excess compensation, proceedings under Section 28-A culminate in an award by the Collector after inquiry, and any person dissatisfied with that award may seek reference to the court under sub-section (3). Since the Collector's award under Section 28-A(2) is itself an award determining compensation payable to the applicant, Section 34 applies to that award, and interest can be granted on the additional amount determined by the Collector.

Conclusion: The Collector is competent to award interest on the additional compensation determined under Section 28-A.

Final Conclusion: The review petitions failed on both grounds, and the earlier dismissal of the civil appeals was maintained.

Ratio Decidendi: Section 28-A is a beneficial provision that must be construed to advance, and not restrict, the right to redetermination of compensation, and the limitation under it runs from the award relied upon for redetermination rather than only the first post-amendment award; the Collector's award under Section 28-A is also capable of carrying interest under Section 34.

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