Compensation cannot be enhanced solely on prior judgments without an evidentiary inquiry.

The Special Land Acquisition Officer (SLAO) determined compensation for the respondent’s acquired land in Bikanalli village at Rs.84,000 per acre, using the sales-statistics method

The respondent sought a reference under Section 64(1) of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 (“2013 Act”)

The Land Acquisition, Rehabilitation and Resettlement Authority, Koppal, fixed compensation at Rs.3,80,000 per acre, relying on an earlier judgment and award

The beneficiary’s appeal challenged that determination, including on the grounds that the Authority had not conducted an inquiry or received evidence and that the SLAO had not been made a party

The respondent did not appear in the appeal

1. Whether the Authority could determine enhanced compensation by relying on an earlier award without conducting an inquiry or giving the parties an opportunity to lead evidence.

2. Whether the matter should be remanded for the Authority to determine the market value after hearing the parties and receiving evidence.

Section 26 of the 2013 Act sets out the parameters for determining market value, which the Authority must consider when examining a reference.

Under Section 60(2)–(4), the Authority has original jurisdiction over references under Section 64, is guided by the principles of natural justice, and must give the parties notice and an opportunity to be heard before disposing of a reference.

Section 64 provides for a reference to the Authority.

In *Manoj Kumar v. State of Haryana*, (2018) 13 SCC 96, the Court stated that a previous judgment may be relied upon only as a last resort when other evidence is unavailable.

The High Court found that the Authority had not conducted an inquiry, received evidence, or considered whether the land in this case was comparable to the land in the earlier matter on which it relied.

It also noted that the parties had not been given an opportunity to lead evidence.

Because the Authority had to assess the SLAO’s valuation against the statutory parameters and determine market value on an adequate evidentiary basis, the earlier award could not substitute for that inquiry.

The Court also considered a Coordinate Bench decision concerning land acquired under the same notification, which had remanded the matter to allow evidence.

The matter was remanded to the Authority to give both parties an opportunity to lead evidence and then determine the actual market value of the acquired land in accordance with law.

The parties were directed to appear before the Authority on 28 October 2026.