Doctrine of precedent and narrow solatium interpretation shape the Supreme Court's reading of land acquisition compensation law.

A Division Bench of two judges may refer a matter to a larger Bench when it doubts the correctness of an earlier larger Bench ruling, because judicial discipline and the doctrine of precedent require smaller Benches to follow binding precedent under Article 141. On land acquisition compensation, section 30(2) of the Land Acquisition (Amendment) Act, 1984 was construed narrowly: enhanced solatium applies only where the underlying award by the Collector or court falls within the statutory period expressly covered by the provision. The broader view extending the benefit to all pending appeals was rejected, and the contrary rulings in Bhag Singh and Mohinder Singh were overruled.

---

---

Issues: (i) Whether a Division Bench of two judges could refer the matter to a larger Bench because it doubted the correctness of an earlier decision of a larger Bench; (ii) whether section 30(2) of the Land Acquisition (Amendment) Act, 1984 extends enhanced solatium to appeals arising from awards made before 30 April 1982.

Issue (i): Whether a Division Bench of two judges could refer the matter to a larger Bench because it doubted the correctness of an earlier decision of a larger Bench.

Analysis: The hierarchy of courts and the need for certainty and consistency in the law require that decisions of a larger Bench bind a Bench of smaller strength. The Court explained that judicial discipline and the doctrine of precedent support reference to a larger Bench when the correctness of an earlier decision is questioned, and that such a course is necessary to maintain consistency in the law declared under Article 141.

Conclusion: The reference to a larger Bench was valid and the preliminary objection was overruled.

Issue (ii): Whether section 30(2) of the Land Acquisition (Amendment) Act, 1984 extends enhanced solatium to appeals arising from awards made before 30 April 1982.

Analysis: Section 30(2) was construed in the context of the amended section 23(2) of the Land Acquisition Act, 1894. The Court held that the words "any such award" restrict the benefit of enhanced solatium to awards made by the Collector or the court between 30 April 1982 and 24 September 1984, and to appeals arising from such awards. The broader view that the benefit extended to all pending appeals, regardless of the date of the underlying award, was rejected as going beyond the language of the provision.

Conclusion: Enhanced solatium under section 30(2) is not available for appeals arising from awards made before 30 April 1982; the contrary view in Bhag Singh and Mohinder Singh was overruled.

Final Conclusion: The Court upheld the validity of the reference, settled the interpretation of section 30(2) in favour of the narrower construction, and directed that the remaining issues in the connected matters be heard separately.

Ratio Decidendi: A later Bench must follow a larger or coordinate Bench decision, and section 30(2) of the Land Acquisition (Amendment) Act, 1984 grants enhanced solatium only where the underlying award by the Collector or court was made within the period expressly specified by the statute.

---