Both the property owner and the lessee have an independent right to appeal the amount of damages awarded; joinder of parties is not necessary. ^[21] On appeal, the court may increase the award to the appellant as long as it determines that the initial award did not accurately reflect the fair market value of the unencumbered fee ^[22] or did not reflect the total aggregate amount of incidental damages. ^[23] Thus, any relief granted on appeal must be through an increase of the total award rather than a reallocation of the lower court’s award. ^[24]

Notes:
^[21] State ex rel. Shaw v. Shofner, supra; State, Department of Highways v. Hurt, 63 Tenn. App. 689, 478 S.W.2d 775 (1972).

^[22] State, Department of Highways v. Hurt, supra.

^[23] State ex rel. Shaw v. Shofner, supra.

^[24] State ex rel. Shaw v. Shofner, supra; State, Department of Highways v. Hurt, supra.