ORDER : 1. Since common questions of law and facts arise for consideration in these writ petitions and as the challenge in all the matters is to identical supplementary awards and consequential orders passed by the acquiring Authority, all the petitions are heard together and are disposed of by this common order. Brief facts: 2. The petitioners are owners of lands/sites acquired by the Bangalore Development Authority (BDA) under the provisions of the Bangalore Development Authority Act, 1976 (‘BDA Act 1976’ for short) for public purposes, including formation of roads and grade separators. Acquisition notifications were issued, and upon completion of statutory formalities, original awards were passed by the competent authority determining compensation payable to the petitioners. 3. The original awards were acted upon. In several cases, the compensation was withdrawn or otherwise accepted, and the awards attained finality. After a lapse of time, the Special Land Acquisition Officer-respondent No.4 passed supplementary awards purporting to withdraw/substitute the original awards. These supplementary awards were approved by the Deputy Commissioner and followed by issuance of consequential award notices. Aggrieved by the said action, the petitioners have approached this Court. Writ petitions averments: 4. It is averred by the petitioners that the original awards were passed in accordance with law and had attained finality, having been acted upon by the petitioners. The Land Acquisition Act, 1894 (‘the LA Act, 1894’ for short) and the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 (‘the Act, 2013’ for short) do not provide for passing of any supplementary award, except to the limited extent of clerical or arithmetical corrections. It is stated that the acquiring authority after passing the original award, became functus officio and lacked jurisdiction to reopen or re-determine the compensation. It is further contended that the supplementary awards were passed without notice or opportunity of hearing in violation of principles of natural justice. It is stated that the impugned supplementary awards, approval orders and consequential award notices are therefore without jurisdiction, arbitrary and liable to be quashed. Statement of objections: 5. That the writ petitions are not maintainable either in law or on facts. The original awards were passed applying the provisions of the Act, 2013 based on the then prevailing legal position. It is stated that the impugned supplementary awards, approval orders and consequential award notices are therefore without jurisdiction, arbitrary and liable to be quashed. Statement of objections: 5. That the writ petitions are not maintainable either in law or on facts. The original awards were passed applying the provisions of the Act, 2013 based on the then prevailing legal position. Subsequently, pursuant to the judgments rendered in Civil Appeals by the Apex Court, it was clarified that the provisions of Act, 2013 were not applicable to the acquisition under the BDA Act, 1976. It is stated that in view of the declaration of law, the BDA resolved to withdraw the awards passed under Act, 2013 and to pass fresh awards under the LA Act, 1894, in order to maintain uniformity and avoid discrimination. It is submitted that the supplementary awards were thus passed as a corrective measure and are legal and valid. The respondents deny that the authority lacked jurisdiction and seek dismissal of the writ petitions. 6. Heard Sri Balaji Raghunathan, learned counsel for the petitioners, Sri Harisha A.S. learned AGA for respondent No.1 and Sri B. Vachan, learned counsel for respondent Nos.2 to 4. 7. Learned counsel for the petitioners reiterates that the declaration of law by the Apex Court, holding that the provisions of Act, 2013 are not applicable to acquisitions under the BDA Act, 1976, does not automatically modify or reopen the concluded awards. In the absence of any express statutory power, the authority could not have treated the original awards as withdrawn or modified. It is further submitted that Section 12A and Section 13A of the LA Act, 1894 do not authorize passing of supplementary award and the authority had become functus officio. 8. Per contra, learned counsel for the respondent-BDA, in support of the statement of objections, submits that the supplementary awards were passed only to bring the award in conformity with the law declared by the Apex Court, and the action taken is corrective in nature and does not suffer from lack of jurisdiction. 9. 8. Per contra, learned counsel for the respondent-BDA, in support of the statement of objections, submits that the supplementary awards were passed only to bring the award in conformity with the law declared by the Apex Court, and the action taken is corrective in nature and does not suffer from lack of jurisdiction. 9. Having heard the learned counsel appearing for the parties, the point that arises for consideration is “Whether the Special Land Acquisition Officer and the Deputy Commissioner had the jurisdiction and authority under the LA Act, 1894, particularly in the light of Sections 12A and 13A, to pass and approve supplementary awards after the original awards had been passed and had attained finality, and whether the authorities had become functus officio, thereby rendering the impugned supplementary awards without jurisdiction?” 10. Upon careful perusal of the pleadings, statement of objections and rival submissions, this Court holds as under: 11. It is not in dispute that the original awards were passed by the competent authority in respect of the lands in question. The records further disclose that the said awards were acted upon, and in several cases, compensation was withdrawn by the petitioners. Once an award is passed and acted upon, the award proceedings attain finality, subject only to such limited statutory corrections as expressly provided under the said Act. 12. It is required to be noted that, on the date when the original awards were passed, the prevailing and binding legal position was that the provisions of the Act, 2013 were applicable to the acquisition under the BDA Act, 1976. The competent authority passed the original awards strictly in accordance with the law as it then stood, based on the judgment holding the field at the relevant point of time. 13. The subsequent judgment of the Apex Court which took a view on the applicability of the Act, 2013 to acquisition under the BDA Act, 1976 is a declaration of law. This would not automatically reopen, modify, or annul concluded awards passed in accordance with law prevailing on the date of their issuance. In the absence of any express statutory provisions permitting the reopening of concluded awards, or specific judicial directions setting aside or modifying individual awards, the acquiring authority could not have treated the original awards as invalid or liable to substitution. In the absence of any express statutory provisions permitting the reopening of concluded awards, or specific judicial directions setting aside or modifying individual awards, the acquiring authority could not have treated the original awards as invalid or liable to substitution. Therefore, the respondents cannot contend that the original awards stood modified merely because the legal position was clarified subsequently. The legality of an award must be tested with the reference to the law prevailing on the date of its passing, and not by applying a later declaration of law retrospectively to unsettle completed proceedings. 14. At this stage, it is necessary to look into Sections 12A and 13A of the LA Act, 1894, which read as under: " 12A. Amendment of award: (1) Any clerical or arithmetical mistake in an award or errors arising therein from accidental slips or omission may, at any time not later than six months from the date of the award, be corrected by the Deputy Commissioner, either on his own motion or on the application of a person interested and the award so corrected shall be deemed to have been amended accordingly. (2) If the award so amended disclosed any over payment, the Deputy Commissioner shall, either immediately after the amendment of the award or after the expiry of the time allowed to make a reference to the court from the amendment of the award, issue a notice to a person to whom over payment was made that if the amount overpaid is not paid back to the State Government within one month after receipt of the notice, the amount overpaid shall be recovered as an arrear of land revenue and after the expiry of the time stated in the notice, the amount shall be so recoverable. 13A. Correction of clerical errors, etc. 13A. Correction of clerical errors, etc. (1) The Collector may, at any time but not later than six months from the date of the award, or where he has been required under section 18 to make a reference to the Court, before the making of such reference, by order, correct any clerical or arithmetical mistakes in the award or errors arising therein either on his own motion or on the application of any person interested or a local authority: Provided that no correction, which is likely to affect prejudicially any person, shall be made unless such person has been given a reasonable opportunity of making a representation in the matter. (2) The Collector shall give immediate notice of any correction made in the award to all the persons interested. (3) Where any excess amount is proved to have been paid to any person as a result of the correction made under sub-section (1), the excess amount so paid shall be liable to be refunded and in the case of any default or refusal to pay, the same may be recovered as an arrear of land revenue.” 15. A conjoint reading of Sections 12A and 13A of the LA Act, 1894 makes it clear that Section 12A permits correction of clerical or arithmetical mistakes within the prescribed period, while Section 13A permits correction of accidental slips or omissions, and mandates notice where such correction is likely to be prejudicial. Significantly, neither provision authorizes withdrawal, substitution or re- determination of an award, nor do they contemplate the passing of a supplementary award. The LA Act, 1894 and the Act 2013 do not recognize the concept of supplementary award replacing an earlier award. The impugned actions though titled as ‘supplementary awards’ in substance amounts to a fresh determination of compensation, which is wholly alien to the statutory framework. Permitting such an exercise would defeat the principles of certainty and finality governing acquisition proceedings and would result in administrative arbitrariness. 16. Once the original award was passed as per the law prevailing at the relevant time, the Land Acquisition Officer exhausted his statutory jurisdiction and became functus officio. Permitting such an exercise would defeat the principles of certainty and finality governing acquisition proceedings and would result in administrative arbitrariness. 16. Once the original award was passed as per the law prevailing at the relevant time, the Land Acquisition Officer exhausted his statutory jurisdiction and became functus officio. The doctrine of functus officio is a latin maxim, meaning ‘once an officer or agency has performed their function, their jurisdiction has come to an end.’ After the Special Land Acquisition Officer determines the compensation and passes a final award under the relevant Act, that award becomes final. The SLAO cannot revise or modify the quantum of compensation awarded. The doctrine of functus officio squarely applies in the present case, as the impugned supplementary awards are not in the nature of clerical or arithmetical corrections, but amount to re-adjudication, which is impermissible. The impugned supplementary awards passed by the Special Land Acquisition Officer, the approval orders passed by the Deputy Commissioner and the consequential award notices are therefore dehors Sections 12A and 13A of the LA Act, 1894 without jurisdiction, and liable to be set aside. The action of the respondents is clearly beyond the scope of the statutory power. Accordingly, the point framed for consideration is answered and this Court pass the following: ORDER: i. The writ petitions are allowed. ii. The supplementary awards passed by the Special Land Acquisition Officer and the order approving the same by the Deputy Commissioner and the consequential award notices impugned in these writ petitions are hereby quashed. iii. It is hereby declared that the original awards were passed in accordance with the law prevailing on the date of their issuance, namely, the applicability of the Act, 2013 and the acquiring authority, having passed the original awards, had therefore become functus officio. iv. Liberty is reserved to the respondents to take such action as is permissible under law. Such liberty shall not be construed as authorizing the reopening, withdrawal, substitution, or re-determination of the original awards, which have attained finality, except to the limited extent of clerical or arithmetical corrections permissible under Sections 12A and 13A of the LA Act, 1894.