Final land acquisition awards cannot be reviewed, and clerical correction powers cannot reopen compensation merits.

An award under the Land Acquisition Act attains finality once filed and notice is issued, and the statute does not confer an express or implied power of review on the Collector. Section 13A is confined to correcting clerical or arithmetical mistakes within the prescribed period and cannot be used to reopen the merits of the award. A so-called review award that reassesses compensation or the legality of structures is therefore beyond jurisdiction and cannot displace the original and supplementary awards. The operative principle is that a final quasi-judicial award cannot be reviewed in the absence of statutory authority.

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Issues: (i) Whether an award made under Section 11 of the Land Acquisition Act, 1894 could be reviewed after it had attained finality; (ii) whether the so-called review award reducing compensation was legally sustainable and whether the appellants were entitled to the compensation awarded under the original and supplementary awards.

Issue (i): Whether an award made under Section 11 of the Land Acquisition Act, 1894 could be reviewed after it had attained finality.

Analysis: The award under the Act becomes final in terms of Section 12 once filed and notice is given to the persons interested. Section 13A is only a limited provision enabling correction of clerical or arithmetical mistakes, and only within the prescribed period. The statute contains no express or implied power of review, and a review cannot be assumed as an inherent power of the Collector. An order styled as a review award, therefore, cannot be treated as a permissible correction when it in substance reopens the merits of the original award.

Conclusion: The review of the award was impermissible and the order made as a review award was without jurisdiction.

Issue (ii): Whether the so-called review award reducing compensation was legally sustainable and whether the appellants were entitled to the compensation awarded under the original and supplementary awards.

Analysis: The deduction made from the original compensation was not a clerical or arithmetical correction but a substantive reassessment of the legality of the structures for which compensation had already been awarded. Such a determination could not be made through Section 13A. Since the original award remained final and the review award was invalid, the compensation as originally awarded, along with the supplementary award, could not be denied.

Conclusion: The reduction in compensation was unsustainable and the appellants were entitled to the compensation under the original award and the supplementary award.

Final Conclusion: The appeals succeeded, the review award and the High Court's judgment were set aside, and the compensation awarded under the acquisition proceedings was restored to the appellants.

Ratio Decidendi: In the absence of an express statutory provision, a quasi-judicial award that has attained finality cannot be reviewed, and a limited power to correct clerical or arithmetical errors cannot be used to reopen the merits of the award.

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