Locus standi in land acquisition references upheld where compensation amount alone was under determination.

A claimant who had contracted to purchase an interest in land acquired under the Land Acquisition Act could seek a reference under section 18 when the court was concerned only with determining compensation, because the proceeding had not yet reached apportionment or identification of persons entitled to the compensation money. A person treated by the Collector as a claimant could ask for the reference and support it, while the question of ultimate entitlement to a share in compensation was reserved for a later stage. Section 54 of the Transfer of Property Act did not bar locus standi at that stage, and the rejection of the reference was set aside.

---

---

Issues: Whether a claimant who had entered into a contract to purchase an interest in land acquired under the Land Acquisition Act could seek a reference under section 18 at the stage when the Court was determining only the amount of compensation, and whether section 54 of the Transfer of Property Act barred such locus standi.

Analysis: The proceeding before the Court below had not reached the stage of apportionment of compensation or determination of the persons entitled thereto. At that stage the only question was the amount of compensation payable for the acquisition. A person who claimed an interest in the compensation money and had been treated by the Collector as a claimant was entitled to ask for a reference and to support it. The question whether he would ultimately be entitled to any share in the compensation was a matter for a later stage. Section 54 of the Transfer of Property Act had no application to the determination then before the Court.

Conclusion: The claimant had locus standi to seek the reference. The lower Court's order rejecting the reference was set aside and the matter was remanded for determination of the amount of compensation payable by Government.

---