Legal fiction for compensation cannot trigger fresh land acquisition declarations or awards; earlier valuation ruling remains binding.

A deemed date created by legal fiction for compensation purposes under land acquisition law could not be extended to require a fresh Section 6 declaration or a fresh award under Sections 11 or 11A. The earlier judgment had upheld the acquisition and altered only the valuation date for compensation, leaving the acquisition itself intact. A challenge to treat that earlier decision as non est for alleged conflict with the statute or Article 142 was rejected, because the prior order remained binding between the parties and its limited compensation benefit could not be unsettle d. The appeals failed and the earlier valuation framework was left undisturbed.

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Issues: (i) Whether the deemed date given to the notification under Section 4(1) of the Land Acquisition Act required a fresh declaration under Section 6 and a fresh award under Section 11 or Section 11A. (ii) Whether the earlier decision upholding the acquisition could be treated as non est or invalid for alleged conflict with the statute or Article 142 of the Constitution of India.

Issue (i): Whether the deemed date given to the notification under Section 4(1) of the Land Acquisition Act required a fresh declaration under Section 6 and a fresh award under Section 11 or Section 11A.

Analysis: The deemed date was created only to benefit the landowners by enabling redetermination of compensation on the basis of enhanced market value. The legal fiction had to be confined to that purpose alone. It could not be extended to import a fresh statutory sequence of declaration and award. The earlier decision had upheld the acquisition and merely altered the valuation date for compensation, while leaving the acquisition intact and permitting possession in accordance with law.

Conclusion: No fresh declaration under Section 6 or fresh award under Section 11 or Section 11A was required.

Issue (ii): Whether the earlier decision upholding the acquisition could be treated as non est or invalid for alleged conflict with the statute or Article 142 of the Constitution of India.

Analysis: The earlier judgment sustained the acquisition proceedings and only granted a deemed date for the limited purpose of compensation. That part of the judgment was not contrary to the statute. The challenge sought to unsettle a binding earlier decision between the same parties, which could not be done in these proceedings. The court declined to disturb the benefit already conferred on the landowners by that earlier order.

Conclusion: The earlier decision remained binding and was not liable to be treated as non est.

Final Conclusion: The appeals failed, the acquisition-related challenge was rejected, and the compensation direction and earlier valuation framework were left undisturbed.

Ratio Decidendi: A deemed date created by legal fiction for a limited statutory purpose, such as redetermination of compensation, cannot be extended to trigger additional statutory requirements unless the order expressly so provides.

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