Additional compensation under Section 30(3) is calculated on market value inclusive of multiplication factors under Section 26.

The petitioners’ lands were acquired under the National Highways Act, 1956 (NHA).

Preliminary notifications were issued under Section 3A of the NHA, and awards were subsequently passed in 2021.

While the market value was determined by applying a multiplication Factor-2 for rural land under Section 26 of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 (the 2013 Act), the petitioners were denied the statutory benefit of 12% additional compensation under Section 30(3) of the 2013 Act on that total value.

The petitioners approached the High Court in March 2026, seeking the additional compensation, statutory interest under Section 80, and benefits related to rehabilitation and infrastructure under the Second and Third Schedules of the 2013 Act.

1. Whether the petitioners are entitled to additional compensation @ 12% per annum under Section 30(3) of the 2013 Act calculated on the market value inclusive of multiplication Factor-2.

2. Whether the petitioners are entitled to statutory interest under Section 80 of the 2013 Act for the unpaid additional compensation.

3. Whether the petitioners can claim benefits under the Second and Third Schedules of the 2013 Act after a delay of approximately four years from the date of the award.

The court primarily applied Section 30(3) of the 2013 Act, which mandates an additional amount @ 12% per annum on the market value from the date of notification to the award or possession.

It relied on the definition of "market value" under Section 3(u) and Section 26, which includes the multiplication factor for rural areas.

The court followed the precedent in Union of India v. Tarsem Singh [(2019) 9 SCC 304], which extended 2013 Act benefits to acquisitions under the NHA.

additional compensation must be computed on the value including the multiplication factor.

Section 80 of the 2013 Act was applied regarding interest on unpaid compensation.

The Court observed that "market value" under the 2013 Act is the end product of all components under Section 26, including the multiplication factor.

Thus, the 12% additional compensation under Section 30(3) cannot be restricted to the "base" market value but must apply to the total value after multiplication.

Since this amount was missing from the original awards, it constituted "unpaid compensation" attracting interest under Section 80.

However, regarding the interest, the Court noted the petitioners' four-year delay in filing the writ and limited the interest period to three years from the award date.

Regarding the Second and Third Schedules (rehabilitation and amenities), the Court held that the petitioners had participated in the acquisition without raising these grievances earlier.

Consequently, these claims were barred by the principles of delay, laches, estoppel, and acquiescence.

It held that the petitioners are entitled to 12% additional compensation under Section 30(3) calculated on the market value inclusive of Factor-2.

It further directed the payment of statutory interest under Section 80 (@ 9% and 15%) on the unpaid additional compensation, but limited this interest to a period of three years from the date of the award due to delay.

The prayers for benefits under the Second and Third Schedules were rejected.

The Competent Authority was directed to pass revised awards within six weeks.