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

The SLAO fixed compensation for the claimant’s acquired land at ₹90,000 per acre, using sales statistics for the period from 25 September 2011 to 25 September 2014.

The claimant sought a reference under Section 64 of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013. The Authority enhanced compensation to ₹3,80,000 per acre, relying on earlier judgments without conducting an enquiry or receiving evidence.

The beneficiary appealed, contending, among other things, that the Authority had not followed the statutory procedure and that the SLAO was a necessary party.

1. Whether the Authority could determine enhanced compensation by relying on earlier judgments without conducting an enquiry or giving the parties an opportunity to adduce evidence.

2. Whether the impugned award should be set aside and the reference remanded for evidence and redetermination of compensation.

Section 60(2) of the 2013 Act gives the Authority original jurisdiction over references under Section 64; Section 60(3) provides that it is not bound by the Code of Civil Procedure but must follow natural justice and may regulate its own procedure; and Section 60(4) requires notice, an opportunity of hearing, and disposal of the reference by an award.

In determining compensation, the Authority must consider the statutory parameters under Section 26.

Relying on Manoj Kumar v. State of Haryana, (2018) 13 SCC 96, the Court observed that a previous judgment may be relied on only as a last resort where other evidence is unavailable.

The Court also followed the approach taken by a Coordinate Bench in MFA No. 100651 of 2025, which had remanded a matter arising from the same notification to permit evidence.

The Authority enhanced compensation without conducting an enquiry, receiving evidence, or assessing whether the land in this case was comparable to land considered in the earlier judgments. It also failed to examine the SLAO’s valuation method against the statutory parameters.

As the parties had not been given an opportunity to lead evidence, and the case arose from the same notification as the matter considered by the Coordinate Bench, the Court concluded that the reference required reconsideration after evidence was received.

The parties were directed to appear before the Authority on 30 October 2026 without further notice.