Interest under Section 80 of the 2013 Act applies to land acquisitions under the Metro Railways Act.

The appellant’s land was acquired under the Metro Railways (Construction of Works) Act, 1978 ("1978 Act"). Following acquisition, the appellant received compensation but challenged the amount before the statutory Authority.

Dissatisfied with the subsequent award, the appellant filed a writ petition. The resulting judgment led to this appeal, primarily centered on the insufficiency of interest granted on the enhanced compensation.

The appellant argued for interest calculation from the date of the Section 10 declaration or the award, whereas the respondents contended that interest provisions of the 2013 Act do not apply to 1978 Act acquisitions.

1. Whether land losers in acquisition proceedings under the 1978 Act are entitled to interest under Section 80 of the 2013 Act.

2. Whether such interest is payable from the date of dispossession, the date of the award, or the date of the statutory declaration.

3. Whether interest should be calculated on the enhanced amount as a single whole or via a bifurcated approach for the initial and excess amounts.

Section 105 of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 ("2013 Act"), which allows for the extension of beneficial compensation provisions to enactments listed in the Fourth Schedule (including the 1978 Act) via government notification.

Central Government Notification dated August 28, 2015, issued under Section 113(1) of the 2013 Act, which mandates uniform application of compensation benefits to "similarly placed" land owners.

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

Section 72 regarding interest on excess compensation awarded by an Authority.

The Court held that the 2015 Notification applies all provisions "relating to determination of compensation" in a blanket fashion; because interest for delayed payment is a necessary concomitant of "compensation payable" and a matter of equity, it is included even if not explicitly named in the Notification.

Regarding the commencement date, the Court rejected the appellant's reliance on Lila Ghosh v. State of W.B., noting that case involved Article 142 powers and did not override the specific language of Section 80, which triggers interest from the date of taking physical possession.

The Court determined that the 2013 Act contemplates a dual interest regime: Section 80 acts as a residuary provision for the initial Collector's award, while Section 72 specifically governs interest on the "excess" amount determined by the Authority.

The Court modified the impugned judgment to award a total interest sum of Rs. 3,05,99,928/-, calculated by segregating interest on the original award (9% for the first year, 15% thereafter) and the excess amount granted by the Authority (9% for the first year, 15% thereafter) from the date of physical dispossession.

A 30-day stay of the judgment was granted upon the respondents' request.