Section 11-A award timing under land acquisition law runs from signing, not service of notice, preserving the acquisition.

For Section 11-A of the Land Acquisition Act, 1894, an award is made when the Collector signs it, not when notice is later served on the landowner. The statutory two-year limit for making the award is therefore not extended by delay in service, and acquisition does not lapse if notice is served after that period. The fact that the award was made near the end of the prescribed period also does not invalidate the acquisition, because the law allows the award to be made up to the last permissible day and courts will not impose a shorter speed requirement.

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Issues: (i) Whether, for the purpose of Section 11-A of the Land Acquisition Act, 1894, the award is made only when notice of the award is served on the landowner, so that the acquisition lapses if such service occurs after the two-year period. (ii) Whether the acquisition could be quashed merely because the award was made towards the end of the statutory two-year period on the ground of delay.

Issue (i): Whether, for the purpose of Section 11-A of the Land Acquisition Act, 1894, the award is made only when notice of the award is served on the landowner, so that the acquisition lapses if such service occurs after the two-year period.

Analysis: The statutory scheme of Section 11-A fixes an outer limit for the Collector to make the award and the consequence of non-compliance is lapse of the acquisition. The expression "make an award" in this context was held to mean the signing of the award by the Collector, not the subsequent service of notice on the person interested. The earlier construction placed on the expression "date of the award" under Section 18, which turns on knowledge of the award for the purpose of seeking a reference, was distinguished because the purpose and consequences of the two provisions are different. Accepting service of notice as the decisive date would make the statutory period depend on variable and uncertain delays in service and could defeat the public purpose of acquisition.

Conclusion: The award was made when it was signed within the two-year period, and the acquisition did not lapse. This issue was decided against the appellant.

Issue (ii): Whether the acquisition could be quashed merely because the award was made towards the end of the statutory two-year period on the ground of delay.

Analysis: The statute itself permits the award to be made up to the last day of the prescribed period, and a court is not to impose a shorter standard of speed merely because the award was made late in the period. The Court noted that undue acceleration may prejudice claimants by depriving them of a proper opportunity to place valuation evidence before the Collector. Since the award was made within the maximum period allowed by Section 11-A, the delay complained of was not fatal.

Conclusion: The challenge based on delay failed, and the acquisition could not be invalidated on that ground. This issue was decided against the appellant.

Final Conclusion: The statutory time limit under Section 11-A controls the validity of the acquisition, and service of notice of the award does not extend or postpone that limit. The appeal failed, and the High Court's decision was affirmed.

Ratio Decidendi: For Section 11-A of the Land Acquisition Act, 1894, an award is made when the Collector signs it, and the statutory period for making the award is not extended by the later service of notice on the landowner.

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