The Allahabad High Court held that a land acquisition award made under the old 1894 law, on a court's specific direction, cannot be challenged just because it did not use the newer 2013 Act's market value formula. The ruling relied on the Supreme Court's earlier decision on how such transitional awards should be treated.
What this changes for a title check
This affects anyone checking whether a compensation award for acquired land is final and cannot be reopened. Some old land acquisition files show an award passed under the 1894 Act even though the acquisition process ran past 2014, when the newer 2013 Act's market value method became available. Landowners sometimes argue such awards should be recalculated using the 2013 Act's higher market value benchmark. This ruling closes that argument where the award was passed strictly to comply with a court's own direction on how to compute compensation. For a title or compensation check, this means the award amount in the file is likely final and not open to a fresh market value challenge on this specific ground, so a lawyer reviewing an acquisition award from this period should note the reason the award was passed before assuming it can still be revised upward.