Strict statutory time limit for land acquisition awards cannot be extended by importing Limitation Act principles or implied exclusions.

Section 11-A of the Land Acquisition Act permits exclusion only of the period during which acquisition proceedings are stayed by a court order, and its two-year limit for making the award cannot be extended by importing Section 12 of the Limitation Act. The Court held that the time taken to obtain a certified copy of the order vacating the stay was not an express exclusion under Section 11-A, unlike provisions where Parliament had specifically provided for such exclusion. It further held that the omission was not a casus omissus capable of judicial correction. The award was therefore beyond time, and the acquisition proceedings lapsed.

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Issues: Whether, for computing the two-year period under Section 11-A of the Land Acquisition Act, the time taken to obtain a certified copy of the order vacating a stay could be excluded, and whether the omission of such an exclusion in Section 11-A could be supplied by invoking casus omissus.

Analysis: Section 11-A requires the award to be made within two years from the date of publication of the declaration, excluding only the period during which the proceedings were stayed by a court order. The provision does not contain any express basis for excluding the time taken to obtain a copy of the order vacating the stay, unlike Section 28A, where Parliament expressly provided for exclusion of the time requisite for obtaining a copy of the award. The Court held that the Limitation Act does not apply to the making of an award under Section 11-A and that there was no scope to import Section 12 principles into that provision. It further held that the omission was not an inadvertent casus omissus, because the legislative scheme showed that where exclusion was intended, it was expressly enacted.

Conclusion: The time taken to obtain a copy of the order vacating the stay could not be excluded, and the award remained beyond the period prescribed by Section 11-A.

Final Conclusion: The acquisition proceedings were held to have lapsed for breach of the statutory time limit, and the appeals were dismissed.

Ratio Decidendi: A court cannot add to Section 11-A of the Land Acquisition Act a further exclusion of time not expressly provided by the legislature, and the period for making the award cannot be extended by importing Section 12 of the Limitation Act or by invoking casus omissus.

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