Comparable sale deeds prevail over mechanically adopted previous awards in determining land acquisition compensation.

The appeals arose under Section 54 of the Land Acquisition Act, 1894, against the award dated 23.01.2017 passed by the Additional District Judge, Panipat, in respect of land acquired in Village Siwah, Tehsil and District Panipat, for construction of a 25 MLD Sewage Treatment Plant.

The Section 4 notification was issued on 28.02.2013, followed by the Section 6 notification dated 16.04.2013.

The Land Acquisition Collector assessed the market value at ₹40,00,000 per acre by award dated 26.09.2013, whereas the Reference Court enhanced it to ₹64,64,102 per acre.

The landowners sought further enhancement, while the State challenged the enhancement.

The Reference Court had principally relied on an earlier award dated 17.11.2016 concerning an acquisition initiated in 2007.

Before the High Court, the landowners relied on sale deeds Exhibits P-11, P-12, P-18 and P-20, while the State relied on Exhibits R-2 and R-4.

Whether the market value of the acquired land should be determined by relying on the earlier award dated 17.11.2016 or on the comparable sale exemplars pertaining to the relevant period?

Whether the market value of the acquired land should be enhanced beyond the amount awarded by the Reference Court, and if so, to what amount per acre?

Whether delay, if any, in filing the connected appeals should be condoned and whether interest should be payable for the delayed period?

The Court applied Sections 4, 6, 18 and 54 of the Land Acquisition Act, 1894, governing notification, declaration, reference to the civil court and appeals against the Reference Court’s award.

It relied on Manoj Kumar v. State of Haryana, 2018 (13) SCC 96, and Ram Kishan (Since Deceased) v. State of Haryana, 2025 SCC OnLine SC 715, for the principle that a previous award is only a piece of evidence and cannot be mechanically treated as binding; its factual foundation, similarity of land, distance, size and the underlying exemplars must be examined.

Comparable sale deeds relating to the relevant period are ordinarily more reliable for determining current market value.

The Court also applied the principles of escalation and de-escalation in land prices, deductions for small-sized plots, and the permissible use of reasonable estimation or “guesstimation” where the evidence does not yield an exact valuation, as approved in New Okhla Industrial Development Authority v. Harnand Singh (Deceased) through LRs, 2024 SCC OnLine SC 1691.

The High Court held that the Reference Court had erred in placing primary reliance on the earlier award relating to the 2007 acquisition, particularly when contemporaneous sale deeds from 2010–2014 were available.

Exhibits P-11 and P-12, executed in 2010, indicated a value of approximately ₹1 crore per acre. Applying approximately 30% escalation for the intervening period and a 40% deduction for the small size of the plots, the Court arrived at approximately ₹78,00,000 per acre.

Exhibit P-18, executed in 2014 for a comparatively larger parcel, supported a value of approximately ₹70,00,000 per acre after de-escalation, while Exhibit P-20, after applying de-escalation and a size deduction, indicated approximately ₹86,00,000 per acre.

The State’s sale deeds, Exhibits R-2 and R-4, disclosed only ₹40,00,000 and ₹35,00,000 per acre respectively, but the Court found the landowners’ exemplars more proximate to the acquired land and more persuasive.

Since the genuineness of the landowners’ sale deeds was not disputed, and the landowners themselves agreed to a valuation of ₹78,00,000 per acre, the Court considered that figure a reasonable assessment of market value.

The landowners’ appeals were allowed to that extent, and the State’s appeals were dismissed.

Any delay in filing the connected appeals was condoned by consent, but the landowners were held not entitled to interest for the delayed period.

Pending applications, if any, were also disposed of.