Karnataka High CourtProperty and Real Estate LawAdministrative and Public Law

KIADB’s 2025 Land Award Quashed As Karnataka HC Orders Fresh 2013 Act Award Despite 2020 Acquisition Notifications

MANJULAv.THE STATE OF KARNATAKA

KIADB’s 2025 Land Award Quashed As Karnataka HC Orders Fresh 2013 Act Award Despite 2020 Acquisition Notifications. MANJULA vs THE STATE OF KARNATAKA. Karnataka High Court. LawLens
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In brief

The question

Whether the general award dated 27 March 2025, made under the Land Acquisition Act, 1894, could stand when it was passed after the substituted Section 30 of the KIAD Act came into force.

The court held

The Court allowed the writ petitions and set aside the general award dated 27 March 2025.

It also directed

It directed the KIADB Land Acquisition Officer to make a fresh award in accordance with the 2013 Act within three months of receiving a certified copy of the order.

Any amount already deposited or released to a land loser is to be adjusted against the fresh award.

No order was made as to costs.

01Facts

The petitioners challenged a general award dated 27 March 2025 made by the Special Land Acquisition Officer, Karnataka Industrial Areas Development Board (KIADB), in respect of their lands.

pp. 14–16

The lands had been acquired under Sections 28(1) and 28(2) of the Karnataka Industrial Areas Development Act, 1966 (KIAD Act), through preliminary and final notifications dated 9 December 2020 and 23 December 2020.

pp. 14–16

The petitioners contended that, because the award was made after the 2020 substitution of Section 30 of the KIAD Act took effect on 5 April 2022, compensation had to be determined under the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 (2013 Act).

pp. 14–16

The State and KIADB argued that the applicable law depended on the date of the preliminary notification.

pp. 14–16

02Issues

i.Whether the general award dated 27 March 2025, made under the Land Acquisition Act, 1894, could stand when it was passed after the substituted Section 30 of the KIAD Act came into force.

pp. 14–18

ii.Whether the petitioners were entitled to a fresh award under the 2013 Act notwithstanding that the acquisition notifications had issued before the amendment took effect.

pp. 15–18

03Law Applied

Section 30 of the KIAD Act, as substituted by Act No. 20 of 2020 with effect from 5 April 2022, provides that specified provisions and the First Schedule of the 2013 Act are deemed to form part of the KIAD Act in respect of lands acquired under its acquisition chapter.

pp. 16–18

The Court applied the rule that an award made after that substitution must be made under the applicable provisions of the 2013 Act, rather than under the Land Acquisition Act, 1894.

pp. 16–18

It also relied on Smt. Anitha and Others v. State of Karnataka and Others, W.P. No. 4627/2024, decided 27 September 2024, which held that post-amendment general awards made under the 1894 Act could not be sustained.

pp. 16–18

Provisions in the judgment · 22 · Linked ones open on LawLens

Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 20 provisionsSection 23Section 26Section 27Section 28Section 29Section 30Section 64Section 65Section 69Section 72Section 73Section 74Section 75Section 76Section 77Section 78Section 79Section 80Section 96Section 1

KARNATAKA INDUSTRIAL AREAS DEVELOPMENT ACT, 1966 Section 28Section 30

04Reasoning

The Court noted that, although the acquisition notifications were issued in December 2020, the impugned award was made on 27 March 2025—after substituted Section 30 came into force on 5 April 2022.

pp. 15–18

Applying the text of Section 30 and the reasoning in Smt. Anitha, the Court concluded that the SLAO could not make the award under the 1894 Act after the substitution.

pp. 15–18

The award was therefore without jurisdiction and illegal; the respondents’ reliance on the dates of the preliminary and final notifications did not alter that conclusion.

pp. 15–18

05Holding

The Court allowed the writ petitions and set aside the general award dated 27 March 2025.

pp. 18–19

It directed the KIADB Land Acquisition Officer to make a fresh award in accordance with the 2013 Act within three months of receiving a certified copy of the order.

pp. 18–19

Any amount already deposited or released to a land loser is to be adjusted against the fresh award.

pp. 18–19

No order was made as to costs.

pp. 18–19
Karnataka High Court

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MANJULAvsTHE STATE OF KARNATAKA

Karnataka High Court · October 27, 2026

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