The manufacturers and carriers of Google’s (GOOG) Android devices have chosen to leave some of the oldest Android phones behind in the race to get new hardware upgraded to the latest Android OS.  Unfortunately, the first Android adopters aren’t going to have access to things like Voice Actions, Adobe (ADBE) Flash and a speedier Web browser.  Even recent high-end phones that are on store shelves aren’t up to date.  Sony(SNE), Dell(DELL) and Samsung haven’t updated their devices yet.

However, according to Phandroid, those older OSes will see a new version of the Android market without having to upgrade the OS in the coming days.  The update is silent and will be pushed from the server side so there is nothing for the user to have to do to see the update.

I’ve got this on my Samsung Galaxy S device that is still running Android 2.1 (after a manual restart) last night.  Users of phones using an OS as far back as Android 1.6 will see the upgrade if they check the market today.  New features include: Better layout, widgets, parallel updates (“Update All”) and more paid apps coverage (more countries).

That last feature opens up more revenue potential for Android.