### Power to Determine Additional Compensation for Uncovered Periods Rests with Competent Authority at First Instance Analysis: The Court held that a claim for compensation for a time duration not covered by a prior award is a fresh claim for additional compensation, not a "review" or "enhancement." Thus, the Competent Authority retains jurisdiction under Section 10(1) of the 1962 Act to determine such compensation "at the first instance," and the doctrine of *functus officio* does not apply to these separate periods of loss.

The appellants (landowners/leaseholders) were affected by the laying of a pipeline by Indian Oil Corporation Limited (IOCL).

Initially, IOCL paid ₹42,12,244 as compensation for a 60-day period based on a Panchnama dated 22.05.2020 which identified the land use as "fisheries".

The appellants sought further compensation for the period beyond 60 days via a representation dated 17.02.2022.

In earlier litigation (WPA 19895 of 2021), the Court directed the Competent Authority to decide this representation.

The Competent Authority subsequently awarded additional compensation, holding it was not functus officio.

IOCL challenged this order in a writ petition (WPA 13787 of 2023), where a Single Bench set aside the award, ruling the Authority lacked power to review its own decision.

1. Whether the Competent Authority’s order was a "review" of a past decision or a fresh determination of compensation in the "first instance" under Section 10(1) for a new period.

2. Whether IOCL was estopped from challenging the jurisdiction of the Competent Authority after consenting to the direction in previous writ proceedings.

3. Whether IOCL could invoke restrictions under Section 9 of the 1962 Act against the landowners when the Panchnama acknowledged the land was used for "fisheries."

Section 10(1) of the Petroleum and Minerals Pipelines (Acquisition of Right of User in Land) Act, 1962, which mandates the Competent Authority to determine compensation in the "first instance".

Section 10(2), which allows parties aggrieved by such determination to approach the District Judge.

Quasi-judicial authorities cannot review their own orders absent express statutory provision as established in S. Sethuraman v. R. Venkataraman and Kalabharati Advertising v. Hemant Vimalnath Narichania.

Rule 4A of the 1963 Rules regarding the binding nature of a Panchnama in assessing damages.

The Court reasoned that the initial compensation was only for a 60-day window, whereas the appellant’s 2022 representation sought compensation for the period after those 60 days for which no award had ever been made.

The Competent Authority was not "reviewing" a previous award but was determining compensation for a distinct, subsequent period for the "first instance" under Section 10(1).

The Court found that since IOCL did not object to the Authority’s jurisdiction during the first writ petition, it effectively waived that objection.

Because the Panchnama (a statutory document under Rule 4A) explicitly recorded the land use as "fisheries," IOCL was estopped from later claiming the appellants violated land-use restrictions under Section 9.

The Court allowed the appeal, set aside the Single Bench order, and directed IOCL to pay the computed compensation within 30 days, granting appellants liberty to approach the District Judge under Section 10(2) for enhancement.