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17. Their Lordships of the Hon'ble Supreme Court in State of Punjab vs. Mst. Qaisar Jehan Begum and rt another, AIR 1963 SC 1604 have held that where the award was never communicated to the party the question is when did the party know the award either actually or constructively. Knowledge of the award does not mean a mere knowledge of the fact that an award has been made.

The knowledge must relate to the essential contents of the award. These contents may be known either actually or constructively. Their Lordships have held as under:

[5] As to the second part of cl. (b) of the proviso, the true scope and effect thereof was considered by this court in Harish Chandra's case, 1962-1 SCR 676: (AIR 1961 SC 1500) (supra). It was there observed that a literal and mechanical construction of the words "six months from the date of Collector's award" occurring in the second part of cl. (b) of the proviso would not be appropriate and "the knowledge of the party affected by the award, either actual or constructive, being an essential requirement of fair play and natural justice, the expression used in the proviso must mean the date when the award is either communicated to the party or is known by him either actually or constructively. Admittedly the award was never communicated to the respondents. Therefore the question before us boils down to this. When did the respondents know the award either actually or constructively? Learned counsel for the appellant has placed very strong reliance on the petition which the respondents made for interim payment of compensation on .

December 24,1954. He has pointed out that the learned Subordinate Judge relied on this petition as showing the respondents date of knowledge and there are no reasons why we should take a different view. It seems clear to us that the ratio of the decision in Harish Chandra's case, 1962-1 SCR 676: (AIR 1961 SC 1500) (supra) is that the party affected by the award must know it, actually or constructively, and the period of six months will run of from the date of that knowledge. Now, knowledge of the award does not mean a mere knowledge of the fact that an award has been made. The knowledge must relate to the essential contents of the award. These rt contents may be known either actually or constructively. If the award is communicated to a party under S. 12 (2) of the Act, the party must be obviously fixed with knowledge of the contents of the award whether he reads it. or not. Similarly when a party is present in court either personally or through his representative when the award is made by the Collector, it must be presumed that he knows the contents of the award. Having regard to the scheme of the Act we think that knowledge of the award must mean knowledge of the essential contents of the award.

26. Their Lordships of the Hon'ble Supreme Court in Rajasthan Housing Board versus New Pink City Nirman .

Sahkari Samiti Limited and another, (2015) 7 SCC 601 have held that the limitation period of six months from date of award for making reference to court commences from the date of actual or constructive knowledge of award. Their of Lordships have held as under: