In Brief
A landowner who obtained a court interim order restraining an acquisition cannot later claim higher compensation under the 2013 Land Acquisition Act solely because no award was declared under the 1894 Act as on 1 January 2014. The Supreme Court held that the period of court-ordered restraint must be excluded when interpreting Section 24(1) of the 2013 Act. Litigants cannot benefit from their own litigation by delaying proceedings and then claiming the advantage of higher compensation. The principle of restitution and the maxim that "an act of court shall prejudice no one" preclude landowners from profiting from restraint orders they obtained. Where authorities were prevented by court order from acting, that cannot be treated as inaction or default triggering the 2013 Act's more generous compensation scheme. Compensation must be determined under the 1894 Act.
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