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Issues: Whether the sole heir of the deceased owner was a "person interested" entitled to seek a reference and receive compensation, and whether the absence of a decision in the award as to the claimant's title attracted Sections 30 and 31(2) of the Land Acquisition Act.
Analysis: The deceased owner died before the award was made, and succession to his property had already devolved upon his sole heir. A claimant asserting such heirship is a "person interested" within the meaning of the Act and may seek a reference under Section 18. The expression "dispute" in Section 30 and Section 31(2) was construed to include not only disputes between multiple claimants but also the case where the Collector is unable or omits to decide the title of a sole claimant. Since the award did not determine the claimant's right, deposit of compensation in court under Section 31(2) was justified. As the claim was to the property itself, and the deceased was a Hindu, Section 212 of the Indian Succession Act governed the title, while Section 214 was not attracted on the facts.
Conclusion: The claimant was entitled to be recognised as the sole heir and to receive the compensation, and the reference was validly made and answered in his favour.
Final Conclusion: The claimant's title to the acquired property having vested before the award, the compensation followed that title and was payable to him.
Ratio Decidendi: Where the owner dies before the award, the sole heir who succeeds to the property is a person interested entitled to claim compensation, and the statutory expression "dispute" in Sections 30 and 31(2) extends to a case where the Collector has not determined the sole claimant's title.