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Issues: (i) Whether a writ petition seeking interest on compensation payable under the Act was not maintainable as a claim for recovery of money. (ii) Whether interest on delayed payment of compensation under Section 26 of the Maharashtra Agricultural Lands (Ceiling on Holdings) Act, 1961 was confined to 3% per annum or could be awarded at a higher rate for the period beyond twenty years.
Issue (i): Whether a writ petition seeking interest on compensation payable under the Act was not maintainable as a claim for recovery of money.
Analysis: A writ petition under Article 226 is ordinarily not used to enforce a pure civil claim for money, but that limitation does not apply where the claim arises from the discharge of statutory duties by the State and its officers. The relief sought was not a bare money claim; it challenged the legality, arbitrariness, and discriminatory treatment in fixing the rate of interest on statutory compensation. The matter therefore involved a public law element and consequential monetary relief could be granted in writ jurisdiction.
Conclusion: The writ petition was maintainable and was not barred merely because monetary relief was sought.
Issue (ii): Whether interest on delayed payment of compensation under Section 26 of the Maharashtra Agricultural Lands (Ceiling on Holdings) Act, 1961 was confined to 3% per annum or could be awarded at a higher rate for the period beyond twenty years.
Analysis: Section 26 regulates payment of compensation through transferable bonds carrying interest at 3% per annum and also permits cash payment where bonds cannot be issued in the prescribed denominations. That statutory scheme governs the interest payable for the initial twenty-year period from the date of possession. However, the section is silent on interest for delay beyond that period. Where the statute is silent, equitable principles govern and reasonable interest may be awarded. The statutory rate could not be applied beyond twenty years as if the silence of the provision excluded equitable relief for the subsequent period.
Conclusion: Interest was payable at 3% per annum for the first twenty years and at 6% per annum thereafter until payment.
Final Conclusion: The appeal succeeded to the extent that the compensation interest was reworked by applying the statutory rate for twenty years and an equitable rate for the subsequent delayed period, and the writ challenge to maintainability was accepted.
Ratio Decidendi: Where a statute prescribes interest only for a defined period in the compensation scheme, the statutory rate governs that period alone, and for delay beyond the period expressly covered, courts may award interest on equitable principles in writ jurisdiction when the dispute arises from public law functions of the State.