In Brief
This case concerns the temporal scope of the LARR Act 2013 when applied to land acquisition proceedings initiated under the LA Act 1894. The DMRC acquired land for the Chattarpur Metro Station project, with the award passed in April 2011 and full compensation deposited by November 2011, both within five years of the 2013 Act's commencement (January 1, 2014). Landowners sought enhanced compensation under the new Act. The Supreme Court held that the proviso to Section 24(2)—which provides for enhanced compensation—applies only when awards are made five or more years before the 2013 Act's commencement. Awards made within five years fall under Section 24(1)(b), where proceedings continue under the old Act. The Court rejected reading the proviso into Section 24(1)(b), as this would render that subsection nugatory and create statutory repugnancy. The appeals were allowed; respondents are not entitled to compensation under the 2013 Act.
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