Facts: Petitioners sought a writ of mandamus to enforce a modified/additional compensation award of Rs.18,34,221/- passed by the Competent Authority for land acquired for National Highway broadening. The original award was challenged by the petitioners who also filed objections stating that the "belting system" should not have been applied. The Competent Authority issued a corrigendum modifying the award.
Procedural Posture: The petitioners filed a writ petition under Article 226 of the Constitution of India in the High Court, seeking a writ of mandamus to direct the National Highway Authority to pay the modified compensation.
Issue: Whether the Competent Authority, after passing an initial award for land acquisition under the National Highways Act, 1956, retains the jurisdiction to modify or issue a supplementary award for the same land, and whether a writ of mandamus can be issued to enforce such a modified award.
Holding: The High Court held that the Competent Authority becomes functus officio after passing the initial award and lacks the jurisdiction to modify or issue a supplementary award. The writ petition was dismissed.
Reasoning: The Court relied on a previous Division Bench ruling in Bhupendrasingh which held that Section 33 of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013, is inapplicable to acquisitions under the National Highways Act, 1956. Once the award is passed, the Competent Authority loses the power to alter it. The Court distinguished the case of Hemant Lalwani, stating that a supplementary award is permissible only when the original award did not determine compensation for a part of the land. In this case, the initial award covered the entire land, and the subsequent modification was deemed without jurisdiction. The court stated, "Once an award is passed for a particular portion of land the competent authority becomes functus officio, to further deal with the same land."