Award
Land Acquisition Act, 1894, S. 23(1-A)
The expression “award” used in S. 23(1-A) suggests that the intention of the legislature was to make the provisions of the said sub-section applicable to cases where the Collector had yet to make his award or the trial Court hearing the reference under S. 18 of the Land Acquisition Act had still to make its award after the coming into force of the said sub-section on September 24, 1984. The expression “award” is to be distinguished from the expression “decree” and hence, it appears that in the absence of any contrary or inconsistent provision in the said Act the provisions of sub-section would not come into play where the award had been made by the Collector earlier as well as by the Reference Court but on the date of coming into effect of the said sub-section, an appeal from the said award might have been pending in a Court. In that case, the Court would not be “awarding” any amount but would be making a “decree” for an amount. (Union of India v. Zora Singh, (1992) 1 SCC 673 (679,680)