Market value fixed at ₹55.93 lakh per acre after 10% escalation and 25% deduction.

The appellants were landowners whose lands in Villages Sunariya Kalan and Sunariya Khurd, District Rohtak, were acquired for construction of a sector road under notifications issued under Section 4 of the Land Acquisition Act, 1894, dated 16 July 2010.

The acquired area was 26.77 acres in Sunariya Kalan and 13.72 acres in Sunariya Khurd.

The Land Acquisition Collector awarded compensation at ₹36,00,000 per acre.

The Reference Court enhanced the market value to ₹41,00,000 per acre for Award No. 1 and ₹39,00,000 per acre for Award No. 2.

The landowners appealed under Section 54 of the 1894 Act, seeking further enhancement and contending that the acquired lands were contiguous and formed part of the development of Sector 21, for which this Court had previously assessed compensation at ₹56,49,560 per acre.

The State opposed mechanical reliance on previous awards and supported the 35% deduction applied by the Reference Court on account of development and size differences.

1. Whether the market value of the acquired land should be enhanced beyond the amount awarded by the Reference Court on the basis of comparable sale deeds and the potentiality and location of the acquired land?

2. Whether the previous awards assessing compensation at ₹56,49,560 per acre could be relied upon, and whether the 35% deduction imposed by the Reference Court was justified?

3. Whether a uniform market value should be determined for the acquired lands situated in the contiguous villages of Sunariya Kalan and Sunariya Khurd?

The Court applied Section 54 of the Land Acquisition Act, 1894, governing appeals from reference awards, along with the principles for determining market value under the 1894 Act.

Under the comparable-sales method, the exemplar sale must be genuine, proximate in time to the Section 4 notification, situated in the vicinity, comparable in nature, and reasonably comparable in size; where differences exist, an appropriate deduction may be made: Shaji Kuriakose v. Indian Oil Corpn. Ltd., (2001) 7 SCC 650.

The Court also relied on New Okhla Industrial Development Authority v. Harnand Singh, 2024 SCC OnLine SC 1691, which requires consideration of the land’s inherent characteristics, future potentiality, and prevailing market conditions.

It further held that collector rates and previous awards should be considered but not applied mechanically; larger parcels are generally preferable exemplars, while deductions may be made for development costs, size, locational advantages, and differences between developed plots and agricultural or undeveloped land.

Previous awards should neither be blindly followed nor rejected outright: Manoj Kumar v. State of Haryana, 2018 (2) RCR (Civil) 815, and Ram Kishan (Since Deceased) v. State of Haryana, 2025 SCC OnLine SC 715.

The Court found that the acquired lands in the two villages were contiguous, that the Collector had awarded a uniform rate, and that the lands were situated in the development area of Sector 21 and connected the Sector 21 Special Zone with the Southern Bypass.

The location demonstrated substantial residential and commercial potential.

Among the sale exemplars, Ex. P-8 involved 1 kanal 3 marlas, was dated 17 September 2009—approximately ten months before the Section 4 notification—and was located abutting and on both sides of the acquired land.

It therefore constituted a more reliable comparable sale than the smaller or more distant transactions, particularly Ex. P-9.

The rate reflected in Ex. P-8 was ₹67,79,130 per acre.

Applying a 10% escalation for the intervening ten months produced ₹74,57,043 per acre.

Although a deduction was warranted because the exemplar land had been used for unauthorised residential construction, the Court held that the Reference Court’s 35% deduction was excessive in view of the acquired land’s location and development potential.

A maximum deduction of 25% was considered appropriate, resulting in a value of ₹55,92,780 per acre, which was rounded to ₹55,93,000 per acre and found broadly consistent with the previous awards.

The market value of the acquired land was enhanced and determined at ₹55,93,000 per acre, with the landowners entitled to statutory benefits under the Land Acquisition Act, 1894.

Any delay in filing the appeals was condoned by consent, but the appellants were held not entitled to interest for the period attributable to such delay.

Pending applications, if any, were also disposed of.