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(a) The award was made beyond one year from the date of publication of the declaration under section 20E(1) of the Act.

(b) The benefit of the first proviso to section 20F(2) of the Act which enabled the competent authority to make the award within an extended period of six months (after the expiry of one year specified in section 20F(2) of the Act) was not available to save the acquisition, as the competent authority failed to record in writing any reason to show that he was satisfied that the delay was caused due to unavoidable circumstances.

(i) Whether the period of one year, stipulated under section 20F(2) of the Act, for making the award, has to be reckoned from the date of publication of the declaration under section 20E(1) of the Act in the official gazette or from the date of any subsequent publication of the declaration in newspapers?

(ii) Whether an award made within six months after the expiry of one year from the date of publication of the declaration, is valid under the first proviso to section 20F(2) of the Act, even if reasons are not recorded by the competent authority in writing to show that he was satisfied that the delay had been caused due to unavoidable circumstances?

9. Though sub-section (2) of section 20F provides that if the award is not made by the competent authority within one year from the date of publication of the declaration, the entire proceedings for acquisition of land shall lapse, the proviso thereto enables the competent authority to make the award within an extended period of six months if he is satisfied that the delay had been caused due to unavoidable circumstances and reasons therefor are recorded in writing. In this case admittedly the competent authority has not recorded any reasons in writing to hold that the delay was due to unavoidable circumstances.

(ii) Sub-section (2) of section 20F requires the award to be made by the competent authority and the first proviso requires the competent authority to record the reasons for the delay. What are "unavoidable circumstances"

leading to the delay which would enable the competent authority to make an award beyond one year, would invariably lead to litigations as to whether there were unavoidable circumstances, whenever the award is made beyond one year. As the consequence of making an award beyond one year but within eighteen months, involving payment of additional compensation, is set out in the second proviso to section 20F(2), there is no need for requiring the competent authority to record reasons in writing showing that the delay was due to unavoidable circumstances.