A claimant cannot pursue an enhancement appeal after recording full satisfaction of the award.

Land belonging to respondent No. 1 was acquired for the appellant institute. After receiving compensation, she sought a reference; the Reference Court enhanced compensation by an award dated 1 August 2022.

The appellant deposited the enhanced amount, interest and statutory benefits in execution proceedings. Respondent No. 1 then filed a memo recording full satisfaction of the award, and the Lok Adalat closed the execution proceedings as satisfied on 11 February 2023.

She later appealed against the Reference Court’s award. The Appellate Court condoned the delay and modified the award; a subsequent execution petition resulted in an attachment warrant against the appellant’s funds. The appellant challenged that decision in this second appeal.

The appeal was brought under Section 54(2) of the Land Acquisition Act.

The judgment cited no precedent or statutory provision addressing whether recording full satisfaction in execution bars a subsequent appeal for enhancement.

The Court applied the principle that a party’s acceptance of the deposited compensation and recorded satisfaction of the award may preclude a later appeal seeking enhanced compensation, particularly where the acceptance was not disclosed to the Appellate Court.

The Court found that respondent No. 1 had received the compensation and, after the appellant deposited the enhanced award amount with interest and statutory benefits, had filed a memo stating that the entire amount was deposited and seeking permission to withdraw it. The Lok Adalat recorded the memo and closed execution as satisfied.

In the Court’s view, respondent No. 1’s later appeal for further enhancement—without disclosing that prior satisfaction—amounted to an abuse of process. It therefore held that the Appellate Court erred in entertaining and allowing the appeal.

Any interim order was discharged, and pending interlocutory applications were disposed of.