Final land acquisition awards could not be reopened for enhanced solatium and interest beyond the 1984 amendment window.

Enhanced solatium and interest under the Land Acquisition (Amendment) Act, 1984 were confined by the transitional scheme in Section 30 to awards and appeals within the statutory window, so final awards made earlier could not be reopened to grant the amended benefits. An order purporting to add such substantive relief after finality was beyond jurisdiction and therefore void. Because a decree passed without jurisdiction is a nullity, the executing court could decline to enforce the High Court's order and treat it as incapable of execution.

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Issues: (i) Whether the benefit of the enhanced solatium and interest introduced by the Land Acquisition (Amendment) Act, 1984 could be extended to cases in which the award of the Collector and the reference court had become final before the amendment came into force. (ii) Whether the executing court could refuse to execute the High Court's order granting such enhanced benefits on the ground that the order was without jurisdiction and a nullity.

Issue (i): Whether the benefit of the enhanced solatium and interest introduced by the Land Acquisition (Amendment) Act, 1984 could be extended to cases in which the award of the Collector and the reference court had become final before the amendment came into force.

Analysis: The transitional scheme under Section 30 of the Land Acquisition Act, 1894 made the amended benefits available only in relation to awards of the Collector or the court made between 30.04.1982 and 24.09.1984, and to appeals against such awards. The awards in the present cases had been made prior to 30.04.1982. The amended provisions in Sections 23(1A), 23(2) and 28 could therefore not be applied to reopen compensation determinations that had already attained finality.

Conclusion: The enhanced benefits under the 1984 amendment were not available to the appellants, and the High Court's orders granting them were not legally sustainable.

Issue (ii): Whether the executing court could refuse to execute the High Court's order granting such enhanced benefits on the ground that the order was without jurisdiction and a nullity.

Analysis: A decree that is passed without jurisdiction is a nullity and may be challenged even in execution. At the same time, Sections 151 and 152 of the Code of Civil Procedure, 1908 do not permit a court to modify a final decree by adding substantive reliefs that were never granted. Since the High Court had no jurisdiction to reopen a final compensation award and confer enhanced statutory benefits by those applications, the resulting order was void and could be disregarded by the executing court.

Conclusion: The executing court was entitled to treat the High Court's order as a nullity and refuse execution of the enhanced benefits.

Final Conclusion: The appeals failed because the statutory amendment did not apply to the finalized awards and the earlier High Court orders granting enhanced solatium and interest were without jurisdiction.

Ratio Decidendi: Transitional benefits under the Land Acquisition (Amendment) Act, 1984 apply only within the period and class of awards specified by the statute, and a final decree cannot be substantively altered through Sections 151 and 152 of the Code of Civil Procedure, 1908; any order passed without jurisdiction is void and can be ignored in execution.

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