Further enhancement of land compensation denied where market value is already settled in synchronous acquisition cases.

The Appellant, owner of land in Village Fazalwas, Gurugram, challenged the compensation awarded for land acquisition initiated under the Land Acquisition Act, 1894 (LA Act) via a 2008 notification

The Land Acquisition Collector originally assessed the value at Rs. 30,00,000 per acre

On reference, the Reference Court enhanced this to Rs. 62,14,421 per acre

In a subsequent appeal (RFA No. 3389 of 2014), the High Court of Punjab and Haryana applied the "belting method," awarding Rs. 1,21,00,000 per acre for land abutting National Highway-8 (up to 5 acres depth) while maintaining the Reference Court’s rate for the interior lands

The Appellant sought further enhancement before the Supreme Court

1. Whether the delay of 846 days in filing the Special Leave Petition should be condoned?

2. Whether the Appellant is entitled to further enhancement of compensation beyond the rates determined by the High Court for land in Village Fazalwas?

The Court applied the Land Acquisition Act, 1894, specifically regarding the determination of market value and statutory benefits like solatium and interest

It relied heavily on the judicial precedent of Krishan Kumar v. State of Haryana and others (2025 SCC OnLine SC 1043), which dealt with the same acquisition notification and identical land tracts in Villages Kukrola and Fazalwas

The Court first condoned the 846-day delay in filing

On the merits, the Court observed that the matter is no longer res integra (aльeady decided) due to the judgment in Krishan Kumar (supra)

In that case, a coordinate bench had specifically examined the correctness of compensation for Village Fazalwas under the same 2008 notification and had declined any further enhancement, dismissing landowner appeals while also dismissing the State's cross-appeals for reduction

Since the Appellant’s land was part of the same subject-acquisition and village, the Court held that the present appeal was squarely covered by the findings in Krishan Kumar, necessitating a dismissal to maintain consistency in judicial determination of market value for the same locality

The Court held that the Appellant is not entitled to further enhancement but remains entitled to the compensation fixed by the High Court plus all statutory benefits (solatium and interest) under the LA Act

The Respondent-Authorities were directed to deposit any balance amount within eight weeks, and the Reference Court was instructed to facilitate the release of deposited funds to the Appellant without delay