Pre-2015 National Highway Awards Governed by 1894 Act for Solatium and Interest

Relevant date is the compensation determination

In Manav Bhanot v. National Highway Authority of India, the Supreme Court clarified which land-acquisition statute governs solatium and interest for acquisitions under the National Highways Act, 1956. The Court treated the competent authority’s determination under Section 3G(1) as analogous to an award.

If that determination was made before January 1, 2015, solatium, interest and interest on solatium are computed under the Land Acquisition Act, 1894. If compensation had not been determined by that date, the beneficial provisions of the 2013 land-acquisition law apply.

Later arbitration does not alter the regime

The fact that an arbitral award or later court challenge occurred after January 1, 2015, does not by itself shift an earlier competent-authority award into the 2013 Act. The Court nevertheless reaffirmed that National Highway landowners are entitled to solatium and interest, following the constitutional invalidation of the exclusion in Section 3J of the National Highways Act.