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Smart Summary

Factual and Procedural Background

These matters are Civil Revision Nos. 3336 and 3337 of 1986, referred to a larger Bench. The core statutory question is whether landowners whose lands were acquired by the State are entitled to compound interest (interest on the compensation plus interest accrued thereon) or only to simple interest (interest on the principal compensation amount).

Chronology of relevant events as stated in the opinion:

  • 13 October 1970: A notification under section 4 of the Land Acquisition Act, 1894 was issued for acquisition of certain land.
  • 27 March 1971: Collector gave the award of compensation.
  • 31 March 1971: Awarded compensation was deposited in the Revenue Deposit under Standing Order No. 75 (Financial Commissioner, Revenue, Punjab), inviting claimants to withdraw by producing title deeds.
  • 23 April 1975: Compensation was ultimately paid on the basis of the award.
  • 14 May 1975: A reference under section 18 of the Land Acquisition Act was made; the learned District Judge, Bhatinda, by order dated 7 January 1986, enhanced the amount of compensation.
  • 10 January 1986: Execution Application No. 3 filed for realisation of decretal amount Rs. 41,95,388.55.
  • 28 January 1986: State deposited the amount of enhanced compensation.
  • 14 August 1986: The learned Additional District Judge, Bhatinda, decided the execution application and allowed recovery in a particular sum that included interest calculated by him.

Legal Issues Presented

  1. Whether claimants (landowners) are entitled to compound interest (i.e., interest on the principal compensation amount as well as interest accrued thereon) or only to simple interest (i.e., interest on the principal compensation amount alone).
  2. Whether the calculation of interest in the execution order (including the quantum and the base on which post-deposit interest was calculated) was legally correct as contended by the State.

Arguments of the Parties

State / Appellant (Government of Punjab) — as represented by Mr. Bhandari and Government Pleader

  • The State contended before the executing court that interest is payable only on the principal amount of compensation and not on interest accrued thereon; interest is not a part of "compensation" for purposes of section 34 of the Land Acquisition Act.
  • Challenging the Additional District Judge's computation, Mr. Bhandari argued that after payment of Rs. 3,07,912.50 and after accounting for additional amounts (12% per annum under section 23(1-A) and solatium at 30% under section 23(2)), the correct balance on which subsequent interest should be calculated was Rs. 9,10,172.85 (totaling Rs. 12,18,785.35 as the amounts paid), and not Rs. 18,90,452.90 as used by the executing court. Thus the execution court's figure of Rs. 11,54,210.36 plus 15% interest was asserted to be incorrect.

Claimants / Respondent (landowners) — as represented by Mr. J.S. Randhawa

  • The claimants' counsel pleaded that landowners are entitled to compound interest on the entire amount — i.e., interest on the principal compensation as well as on interest accruing thereon — and therefore there was no infirmity in the computation made by the Additional District Judge.

Table of Precedents Cited

Precedent Rule or Principle Cited For Application by the Court
Satinder Singh & others v. Umrao Singh & another, AIR 1961 Supreme Court 908 Holds claimants are entitled to interest on compensation for the period between taking possession and payment; interest is not technically "damages" but a substitute for immediate compensation; sections 23(1-A), 28 and 34 provide for payment of interest. The court treated Satinder Singh as settled law establishing entitlement to interest on compensation but relied on it to show that interest is awarded on the principal amount and does not necessarily support compound interest.
Revenue Divisional Officer, Guntur v. Vasireddy Rama Bhanu Bhupal and others, AIR 1970 Andhra Pradesh 262 Relied upon by claimants in support of interest claims (followed Satinder Singh). Noted that that decision, like others cited by claimants, did not hold that compound interest must be awarded; instead it followed Satinder Singh's principles on entitlement to interest.
Lalsaheb Nabin Chandra Bhani Deo and another v. The State of Orissa, AIR 1975 Orissa 126 Relied upon by claimants in their submissions regarding interest on compensation. Observed in the opinion that this case did not hold that compound interest should be awarded and followed the law in Satinder Singh.
Smt. Tribeni Devi and others v. State of Bihar, AIR 1982 Patna 77 Relied upon by claimants in relation to interest entitlement. Court noted that this decision also did not establish an obligation to award compound interest; it followed the law in Satinder Singh.
R.D. Suryanarayana Rao v. The Revenue Divisional Officer, Guntur, AIR 1969 Andhra Pradesh 55 (Full Bench) Held that interest accruing on compensation is not part of compensation and should be treated as distinct for purposes of the Land Acquisition Act; considered whether court-fee could be demanded on interest payable under section 34. The opinion treated this Full Bench decision as establishing that interest is distinct from compensation and therefore is not to be treated as merged into compensation for subsequent interest calculations.
Patel Anandilai Hisa Lal v. Addl. Spl. Land Acquisition Officer, AIR 1965 Guj. 212 Bench of Gujarat High Court reached a conclusion analogous to the Andhra Full Bench on similar court-fees provisions; treated interest as distinct from compensation. Used by the Andhra Full Bench (and noted in the opinion) to support the view that interest is distinct and not part of the principal compensation.
National Insurance Co. v. Life Insurance Corporation, AIR 1963 SC 1171 Referred to in the Andhra Pradesh Bench discussion (cited by Bhagwati, J.) on the nature of interest as substitute for possession. Referenced as part of the authorities supporting the principle that interest is a substitute right, not damages, and supports the distinction between principal and interest.
Panna Lal and another v. Nihai Chand, AIR 1922 Privy Council 46 Privy Council decision holding that compound interest could not be awarded by Courts under the section (pre-1956 understanding). Relied on in the opinion as authority that compound interest was not intended to be awarded; supported the historical practice of altering compound interest claims to simple interest.
Jewan Lal Daga and another v. Nilmani Chaudhuri, AIR 1928 Privy Council 80 Privy Council decision to the same effect as Panna Lal: Courts should not award compound interest under the relevant provision. Used as historical authority showing compound interest was not to be granted; contributed to the line of cases modifying decrees to simple interest.
Shivaprasad Singh v. Prayagkumari Debee and others, AIR 1935 Calcutta 39 Example of High Court practice modifying decrees to change compound interest claims into simple interest. Referenced as part of the lineage of decisions where courts converted compound-interest claims into simple interest awards.
M.V. Mhalinga Aiyar v. Union Bank Ltd., AIR 1943 Madras 216 Another example of High Court practice altering compound interest to simple interest. Referenced to show historical practice consistent with denying compound interest and awarding only simple interest.
Sigappiachi and others v. M.A.P.A. Palaniappa Chettiar, AIR 1972 Madras 463 Also cited among High Court decisions moderating compound interest claims. Referenced as part of authorities that courts have used to restrict compound interest awards to simple interest.
Food Corporation of India v. Samana Cooperative Marketing cum Processing Society Ltd., Samana Mandi, 1987 (1) CLJ (C. Cr. & Rev.) 778 Single Bench decision holding that interest could be awarded only on the principal sum adjudged and not on the amount of interest adjudged. Cited as recent authority consistent with the conclusion that interest is to be awarded only on the principal and not on interest accrued (i.e., against compound interest).

Court's Reasoning and Analysis

The court's analysis proceeded by close textual and precedential examination of the Land Acquisition Act provisions and the Code of Civil Procedure as amended. The principal steps in the reasoning are:

  1. Statutory framework: The court reproduced and examined sections 23(1-A), 28 and 34 of the Land Acquisition Act, 1894. These provisions explicitly provide for payment of interest on compensation (including a higher rate after one year in certain situations).
  2. Distinguishing principal and interest: The court concluded from a scrutiny of the Act that nowhere is the award of compound interest (i.e., interest on interest) provided for. The statutory language contemplates interest being payable on the principal amount of compensation and treats interest as distinct from compensation.
  3. Precedential support: The court relied on authoritative decisions (notably Satinder Singh (AIR 1961 SC 908) and the Full Bench of the Andhra Pradesh High Court in R.D. Suryanarayana Rao) to show the settled principle that claimants are entitled to interest as a substitute for immediate compensation, but that interest is not to be treated as forming part of the principal compensation for the purpose of awarding further interest.
  4. Historical and procedural-law support: The court examined prior practice under the Code of Civil Procedure (section 34) and the significant amendment effected by the Civil Procedure Code (Amendment) Act, 1956 (Act No. 66 of 1956). The amendment replaced the words "aggregate sum so adjudged" with "principal sum", and the Joint Committee's report explicitly stated Parliament's intent that "interest should not be awarded on interest but only on the principal sum."
  5. Privy Council authority and High Court practice: The court noted Privy Council decisions (Panna Lal and Jewan Lal Daga) and various High Court decisions illustrating that compound interest was not intended to be awarded and that courts historically modified decrees to restrict awards to simple interest.
  6. Application to the facts: Given the statutory wording, the amendment of section 34 of the CPC, and the line of authority, the court held that compound interest on the aggregate of compensation plus accrued interest was not supportable in law and that the executing court's calculation premised on compound interest was not correct.

Holding and Implications

Core Ruling: The revision petitions filed by the State of Punjab are allowed; the impugned order of the Additional District Judge, Bhatinda, is set aside.

Consequences and immediate implications as stated in the opinion:

  • The Additional District Judge is directed to work out the correct amount while allowing the execution applications in the light of this judgment — i.e., having regard to the legal conclusion that interest is to be awarded on the principal compensation amount (simple interest) and not on interest already accrued (no compound interest).
  • There shall be no order as to costs.

The opinion does not elaborate broader doctrinal consequences beyond directing recalculation in the execution proceedings; it grounds the ruling on statutory language, the 1956 amendment to section 34 CPC and consistent precedent showing that compound interest is not to be awarded.

    State Of Punjab Petitioner, v. The Scheduled Caste Co-Operative Land Owning Society Ltd. Bhatinda .

    M.R Agnihotri, J. — In these two Civil Revision Nos. 3336 and 3337 of 1986, which have been referred for decision by a larger Bench, the question of law involved is, as to whether the landowners whose lands have been acquired, by the State are entitled to the payment of interest, that is, interest on the principal amount of compensation including the amount of interest accrued thereon, or to simple interest, that is, interest on the principal amount of compensation awarded only, and not on the interest accrued thereon.

    2. Briefly stated, the facts are that on 13th October 1970, a notification under section 4 of the Land Acquisition Act, 1894, was issued for the acquisition of certain land. The award was given by the Collector on 27th March, 1971, and on 31st March, 1971, the amount of compensation as awarded by the Collector was deposited in the Revenue Deposit in accordance with the provisions of Standing Order No. 75 issued by the Financial Commissioner, Revenue, Punjab, calling upon the claimants to withdraw the amount of compensation by producing the respective title deeds of the land acquired, in their favour. Ultimately, the compensation was paid on the basis of the award on 23rd April, 1975. Thereafter, a reference under section 18 of the Land Acquisition Act, 1894, was made on 14th May, 1975, and the learned District Judge Bhatinda, vide his order dated 7th January, 1986, enhanced the amount of compensation. On the basis of the order of the enhancement of compensation. Execution Application No. 3 of 10th January, 1986, was filed for realisation of the decretal amount, that is, Rs. 41,95,388.55. The amount, of compensation as enhanced by the learned District Judge was deposited by the State on 28th January, 1986. This execution application has been decided by the learned Additional District Judge, Bhatinda, on 14th August, 1986.

    3. Contesting this application before the Executing Court, the State of Punjab took the stand that interest was payable only on the principal amount of compensation and not on the interest accrued thereon, as the interest was not a part of the compensation payable to the claimants under section 34 of the Land Acquisition Act. The learned Additional District Judge, Bhatinda, rejected the contention of the Government Pleader and took the view that according to section 34 of the Land Acquisition Act, interest was to be paid on the amount of compensation till that amount was deposited. When the Government did not pay the amount to the decree-holder, he goes on getting interest on the principal but when some amount out of that was paid and the balance remains, that balance amount becomes the compensation and interest was to be calculated on the balance amount that remained to be paid. Consequently, the execution application was allowed holding that the “decree-holder is entitled to recover Rs. 11,54,210.36 (Rs. 13,33.14631 minus Rs. 1,78,935.95 deposited vide cheque dated 28-7-86) plus interest at the rate of 15% on Rs. 13,33,146.31 from 28-6-1986 to 28-7-1986.”

    Challenging the order of the learned Additional District Judge, Bhatinda, it has been contended on behalf of the State that the calculation of the amount of interest made in the impugned order is not correct. According to Mr. Bhandari, on payment of the amount of Rs. 3,07,912.50, out of the total amount of enhanced compensation and the additional amount at the rate of 12 per cent annum payable thereon under section 23(1-A), and solatium at the rate of 30 per cent per annum thereon under section 23(2) of the Land Acquisition Act, totalling Rs. 12,18,785.35, the balance amount on which interest at the rate of 15 per cent per annum was to be calculated for the period subsquent to 23rd April, 1975, should have been Rs. 9,10,172.85 and not Rs. 18,90,452.90. Consequently, the amount of Rs. 11,54,210.36 as calculated by the learned Additional District Judge, Bhatinda, plus 15 per cent interest thereon, was not in accordance with law.

    4. On the other hand, Mr. J.S Randhawa, learned counsel appearing on behalf of the respondent, has pleaded that the lanldowners are entitled to the payment of compound interest on the entire amount that is, the principal amount of compensation as well as the interest accruing thereon. Hence, there was no infirmity in calculation of the amount, made by the learned Additional District Judge, Bhatinda.

    5. Law relating to acquisition of land and payment of compensation therefore, is almost a century old in India and the question regarding the payment of interest on the amount of compensation has also been the subject matter of litigation in various forums during this long period.

    6. As has been settled by their Lordships of the Supreme Court in Satinder Singh and others v. Umrao Singh and another, AIR 1961 Supreme Court 908, where lands are acquired under the Land Acquisition Act and the claimants are awarded compensation, the claimants are entitled to interest on the amount of the compensation, for the period between the taking of possession of the land by the State and payment of compensation by it to the claimants. When a claim for payment of interest is made by a person whose immovable property has been acquired compulsorily he is not making claim for damages properly or technically so called; he is basing his claim on the general rule that if he is deprived of his land he should be put in possession of compensation immediately; if not in lieu of possesssion taken by compulsory acquisition, interest should be paid to him. On the said amount of compensation. For payment of interest, sufficient and adequate provision has been made in sections 23(1-A) 28 and 34 of the Land Acquisition Act, 1894. These provisions are reproduced below:—

    “23. Matters to be considered in determining compensation.—(1) In determining the amount of compensation to be awarded for land acquired under this Act, the Court shall take into consideration—

    (1-A) In addition to the market-value of the land, as above provided, the Court shall in every case award an amount calculated at the rate of twelve per centum per annum on such market-value for the period commencing on and from the date of the publication of the notification under Section 4, subsection (1), in respect of such land to the date of the award of the Collector or the date of taking possession of the land, whichever is earlier.

    Explanation.—In computing the period referred to in this sub section, any period or periods during which the proceedings for the acquisition of the land were held up on account of any stay or injunction by the order of any court shall be excluded.” “28 Collector may be directed to pay interest on excess compensation.—If the sum which, in the opinion of the Court, the Collector ought to have awarded as compensation is in excess of the sum which the Collector did award as compensation, the award of the Court may direct that the Collector shall pay interest on such excess at the rate of nine per centum per annum from the date on which he took possession of the land to the date of payment of such excess into Court:

    Provided that the award of the Court may also direct that where such excess or any part thereof is paid into Court after the date of expiry of a period of one year from the date on which possession is taken, interest at the rate of fifteen per centum per annum shall be payable from the date of expiry of the said period of one year on the amount of such “excess or part thereof which has not been paid into Court before the date of such expiry.”

    “34. Payment of interest.—When the amount of such compensation is not paid or deposited on or before taking possession of the land, the Collector shall pay the amount awarded with interest thereon at the rate of nine per centum per annum from the time of so taking possession until it shall have been so paid or deposited:

    Provided that if such compensation or any part thereof is not paid or deposited within a period of one year from the date on which possession is taken, interest at the rate of fifteen per centum per annum shall be payable from the date of expiry of the said period of one year on the amount of compensation or part thereof which has not been paid or deposited before the date of such expiry.”

    7. From a scrutiny of the aforesaid statutory provisions, it would be evident that nowhere it has been provided in the Land Acquisition Act that compound interest has to be awarded to the claimants, that is, on the principal amount of compensation as well as on the amount of interest which has accrued thereon. All what has been provided for is, that interest has to be awarded on the principal amount of compensation it self and not on the interest accruing thereon. That is why the argument on behalf of the claimants proceeds further to contend, that interest is certainly part of of compensation and once interest has been awarded on the principal amount of compensation, the amount of simple interest accruing thereon gets added and merged with the principal amount of compensation and it is on the aggregate amount of principal compensation and interest accrued thereon, that further interest has to accrue on the entire aggregate amount. Though in support of this proposition of the claimants, reliance has been placed on the Revenue Divisional Officer Guntur, v. Vasireddy Rama Bhanu Bhupal and others, AIR 1970 Andhra Pradesh 262, Lalsaheb Nabin Chandra Bhani Deo and another v. The State of Orissa, AIR 1975 Orissa 126, and Smt. Tribeni Devi and others v. State of Bihar, AIR 1982 Patna 77, yet in none of these cases it has been held that compound interest has to be awarded on the aggregate amount, that is, the principal amount of compensation as well as the interest accruing thereon Rather, the learned Judges deciding the aforesaid cases have followed the law laid down in Satinder Singh's case (supra) to hold that even on equitable principles where interest has not been claimed specifically, the claimants were entitled to the same on the amount of compensation.

    8. On the other hand, the legal position has been made sufficiently clear by a Full Bench of Andhra Pradesh High Court in R.D Suryanarayana Rao v. The Revenue Divisional Officer, Land Acquisition Officer, Guntur, AIR 1969 Andhra Pradesh 55, in which P. Jaganmohan Reddy, C.J as his Lordship then was speaking far the Court, held that the interest accruing on compensation was certainly not a part of compernsation and it was to be treated as distinct from compesation for the purpose of Land Acquisition Act. Their Lordships of the Andhra Pradesh High Court were considering the question as to whether court-fee could be demanded on the interest payable under section 34 of the Land “Acquisition Act on compensation for the compulsory acquisition of Land. Relying on a Bench decision of the Gujarat High Court in Patel Anandilai Hisa Lal v. Addl. Spl. Land Acquisition Officer, AIR 1965 Guj. 212, their Lordships held as under:—

    “In a recent case, a Bench of the Gujarat High Court in Anandilai v. Addl. Spl. Land Acquisition Officer, AIR 1965 Guj 212, arrived at a similar conclusion on analogous provisions of Section 7(1) of the Bombay Court fees Act which like Section 48 of the Andhra Pradesh Court fees Act also provided that the amount of fee payable under the Act on the memorandum of appeal against an order relating to compensation under any Act for the time being in force for the acquisition of land for public purposes shall be computed according to the difference between the amount awarded and the amount claimed by the appellant Bhagwati, J. after referring to the case of AIR 1961 SC 908 (supra) (Satinder Singh's case) and the case of National Insurance Co v. Life Insurance Corporation, AIR 1963 SC 1171, said;

    ‘…It is now well settled that the right to receive interest is in substitution of the right to retain possession of the land and when a claim for payment of interest is made by a person whose immoveable property has been acquired compulsorily, he does not make a claim for damages properly or technically so called but he bases his claim on the general rule that if be is deprived of his land, he should be put in possession of the compensation immediately; if not, in lieu of possession taken by compulsory acquisition interest should be paid to him on the amount of compensation.’

    Continuing further. Bhagwati, J. observed:

    ‘…Moreover the scheme of the Land Acquisition Act, 1894, itself shows that interest is treated as distinct from compensation for the purposes of that Act. Interest cannot, therefore, be regarded as forming part of compensetion and the expressions ‘amount awarded’ & ‘amount claimed’ cannot on a true construction include the amount of interest claimed by the appellant in the memorandum of appeal… The claim for interest on the additional compensation claimed in the memorandum of appeal would stand or fall with the decision of the main claimand being merely an adjunct of the main claim, no Court-fee would be payable on it.”

    9. Apart from the Land Acquisition Act. even under the ordinary law of the land, as governed by the Code of Civil Procedure, the position of law with regard to the payment of interest remains the same. Prior to 1956, some doubt was, of course, present in the mind of the Courts, as to whether interest was to be paid on the principal amount decreed as well as on interest accrued thereon. But even at that time, by interpreting section 34 of the Code of Civil Procedure, as it stood before 1956, the Privy Council in two decisions reported as Panna Lal and another v. Nihai Chand, AIR 1922 Privy Council 46. and Jewan Lal Daga and another v. Nilmani Chaudhuri, AIR 1928 Privy Council 80, held that compound interest could not be awarded by the Courts as Section 34 or its principle never intended to be used as a means for providing for compound interest but to relieve the debtor of a harsher rate of interest. Following these two judgments of the Privy Council, the High Courts in the country started modifying the decrees by changing the nature of interest from compound to simple, as was done in Shivaprasad Singh v. Prayagkumari Debee and others, AIR 1935 Calcutta 39, M.V Mhalinga Aiyar v. Union Bank Ltd. Kumbakonam, AIR (30) 1943 Madras 216, and Sigappiachi and others v. M. A.P.A Palaniappa Chettiar, AIR 1972 Madras 463.

    10. section 34 of the Code of Civil Procedure, as it stands at present, reads as under:—

    “34. Interest.

    (1) Where and in so far as a decree is for the payment of money, the Court may, in the decree, order interest at such rate as the Court deems reasonable to be paid on the principal sum adjudged, from the date of the suit to the date of the decree, in addition to any interest adjudged on such principal sum for any period prior to the institution of the suit, with further interest at such rate not exceeding six per cent, per annum, as the Court deems reasonable on such principal sum from the date of the decree to the date of payment, or to such earlier date as the Court thinks fit.”

    By the Civil Procedure Code (Amendment) Act (66 of 1956), the words ‘on such principal sum’ have been substituted for the words “on the aggregate sum so adjudged.” Before this amendment, the ‘aggregate sum’ contemplated the aggregate of the principal sum adjudged, the interest from the date of suit to the date of decree and the pre-suit interest. The section classifies the interest awardable after the date of the suit into two classes—

    (1) Interest on the principal sum adjudged from the date of suit to date of decree; and

    (2) Interest on such principal sum from date of decree to date of realisation or to such earlier date as the Court thinks fit.

    Thus, interest awardable from the date of the plaint to the date of decree, under the section as it stands now, will be only upon the principal sum and not on the whole amount including interest claimed by the plaintiff. Before the above-mentioned amendment of section 34 by Act No. 66 of 1956, further interest was awardable on the aggregate of the principal and interest as on the date of the decree but it was not compound interest but only interest on a fixed sum declared to be due by the decree. (Reference may be made to AIR Commentaries on the Code of Civil Procedure by Chitaley, 10th Edition. Vol. I, pages 460 to 467)

    11. The intention of the Parliament, while amending section 34 of the Code of Civil Procedure, by Act No. 66 of 1956, would be clear from the repot of the Joint Committee on the Bill as published in the Gazette of India Extraordinary, Part II, Section II, dated December 13, 1955. Para 11 of the Report relating to Clause 2 of the Bill seeking amendment of section 34 reads as under:—

    “Section 34 of the Code empowers a Court to award further interest from the date of the decree upto the date of payment on the ‘aggregate sum’ which comprises principal sum with interest accrued thereon. The Committee are of the opinion that interest should not be awarded on interest but only on the principal sum. Suitable amendment has accordingly been incorporated in this clause.”

    From the aforesaid amendment made in section 34 of the Code of Civil Procedure, it becomes clear that the intention of Parliament is against the grant of compound interest by the Courts, that is, on the principal amount as well as on the interest accrued thereon. Similar view has been taken recently in a Single Bench decision of this Court in Food Corpn. of India v. Samana Cooperative Marketing cum Processing Society Ltd., Samana Mandi, 1987 (1) CLJ (C. Cr. & Rev.) 778, wherein J.V Gupta, J. held as under:—

    “From the perusal of the said section, it is quite evident that the Court could order interest on the principal sum adjudged from the date of the suit. Since principal sum adjudged is Rs. 65 625/- the interest could be awarded only on that amount and not on the amount of interest, which sum was adjudged as Rs. 23 375/-.”

    12. In view of what has been held above, we have no hesitation in allowing both the revision petitions filed by the State of Punjab and in setting aside the order under revision passed by the Additional District Judge, Bhatinda, who may now work out the amount by allowing the execution applications in the light of this judgment. There shall be no order as to costs.

    I agree.

    Sd/- D.S Tewatia

    Chief Justice.

    Land Acquisition Act.

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    State Of Punjab Petitioner, v. The Scheduled Caste Co-Operative Land Owning Society Ltd. Bhatinda .
    (Oct 19, 1987)