Market value determination based on older notifications is unsafe; fair compensation must reflect current market rates.

The appellants’ lands in villages Lunva and Mandali (District Mehsana) were acquired for public purposes including road construction and the Dharoi–Vatrak Irrigation Canal project.

For Lunva (F.A. 2304/2021), Section 4 notification was published on 20.02.1999.

For Mandali, the notification was published on 03.09.1998.

The Special Land Acquisition Officer awarded compensation between Rs. 3.00 to Rs. 10.00 per sq. mtr.

On reference under Section 18, the Reference Court enhanced the compensation by relying on a 1986 award (village Nortol), adding approximately Rs. 12.00 to Rs. 18.30 per sq. mtr.

The claimants appealed, seeking further enhancement based on contemporaneous acquisitions in adjoining villages for the same project.

1. Whether it is legally sustainable for the Reference Court to determine market value based on an exemplar (previous acquisition) where the Section 4 notification was published thirteen years prior to the subject acquisition

2. Whether the Reference Court is bound by the specific amount claimed by the land owner, or if it has a duty to award just and fair compensation based on true market value

The Court primarily applied Section 25 of the Land Acquisition Act (as amended in 1984), which mandates that compensation awarded by the Court shall not be less than the amount awarded by the Collector, removing the previous cap on the maximum claimable amount.

It relied on the precedent General Manager, ONGC v. Rameshbhai Jivanbhai Patel (2008), which held that relying on exemplars with a time gap exceeding five years is unsafe.

Furthermore, it applied the doctrine from Narendra v. State of Uttar Pradesh (2017) and Ashok Kumar v. State of Haryana (2016), establishing the Court's duty to award "just and fair" compensation irrespective of the specific claim made by the owners.

The Court found that the Reference Court committed a serious error by using the village Nortol (1986 notification) as a benchmark for a 1999 acquisition, a gap of 13 years, violating the 4-5 year safety limit established in Rameshbhai Jivanbhai Patel.

The Court rejected the State's argument of estoppel—that claimants were bound by their reliance on the Nortol award—ruling that the Reference Court acts as a specialized body to determine true market value rather than a strict civil court.

Applying parity, the Court noted that a Coordinate Bench in First Appeal No. 1627 of 2013 had already fixed the market value for the same project and village at Rs. 134.10 per sq. mtr. based on a Division Bench judgment regarding the adjoining village Khatasana.

Since these lands were acquired for the same project during the same period, the Court determined that the "domino effect" necessitated equal compensation.

The State was directed to deposit the enhanced amount within twelve weeks.

For F.A. 2304/2021, interest was denied for the delayed period as the claimants had previously foregone it.