### Market Value Determination and Judicial Parity in Land Acquisition Compensation The Court enhanced land compensation to ₹2,07,500 per bigha, mandating uniform market value determination for all landowners under the same notification based on judicial parity and proved sale exemplars.

The land in Village Kilokari was acquired by the Government for the channelization of the Yamuna River via a Section 4 Notification dated 23.06.1989

The Land Acquisition Collector (LAC) issued Award No. 14/1992-93, fixing compensation at ₹27,344/- per bigha based on agricultural rates with a 15% annual deduction for the land being 'Sailabi'

Aggrieved, the appellants sought a reference under Section 18 of the Land Acquisition Act, 1894. The Reference Court enhanced the market value to ₹89,600/- per bigha, placing reliance on coordinate awards for the same village

The Appellants filed this appeal under Section 54 of the Act, seeking further enhancement to match the judgment in Bed Ram v. Union of India (LA.APP. 59/2007), which dealt with the same notification and village but was decided while the present appeal was inadvertently pending

1. Whether the market value determined by the Reference Court at ₹89,600/- per bigha was adequate or required enhancement in light of subsequent judicial determinations for the same area

2. Whether the principle of parity and judicial discipline necessitates the application of the rates determined in the lead case of Bed Ram v. Union of India to the present appellants

The Court primarily applied Section 54 of the Land Acquisition Act, 1894, which grants appellate jurisdiction to re-appreciate evidence and methodology for market value determination

It relied on the principle of parity and judicial discipline, ensuring similar compensation for similarly situated landowners acquired under the same notification

The Court also integrated the Doctrine of Parity as reinforced by Section 28A of the LA Act, which mandates that once a particular rate of compensation is judicially determined for land under a specific notification, the benefit must extend to all affected persons

It followed the precedent set in Union of India v. Ram Lal & Ors. regarding the rejection of arbitrary ‘Sailabi’ classifications

The Court observed that this appeal was identical in facts, evidence, and legal questions to the Bed Ram batch decided on 26.09.2025

In that case, the Court had rejected the LAC’s ‘Sailabi’ classification due to lack of evidence and recognized the land's significant development potential

A registered Sale Deed dated 17.03.1988 for Village Kilokari, reflecting ₹2,07,500/- per bigha, was accepted as the most proximate and reliable exemplar

The High Court held that since the evidentiary record—including additional evidence recorded under Supreme Court directions—was identical for all appeals in this notification batch, independent re-adjudication was unnecessary

Applying judicial discipline, the Court held that any deviation from the Bed Ram rate would result in arbitrary and discriminatory treatment of the appellants

The Appellant is entitled to the balance amount (after deducting the ₹89,600/- already received) along with 30% solatium under Section 23(2), 12% additional amount under Section 23(1A), and interest at 9% for the first year and 15% thereafter on the enhanced amount

The Court concluded that under Section 28A of the LA Act, the benefit of a judicially determined rate must be extended to all persons whose land was acquired under the same notification