Previous valuation of contiguous land may be adopted with appropriate escalation for the intervening period.

The appellants-landowners challenged the common award dated 30 September 2010 passed by the Additional District Judge, Nuh, which dismissed their references seeking enhancement of compensation.

Their land situated in Village Rewasan, Tehsil Nuh, District Mewat, measuring 210 Kanals 12 Marlas, was acquired for construction of a toll plaza and connecting National Highways pursuant to notifications under Sections 4 and 6 of the Land Acquisition Act, 1894, dated 11 December 2007 and 17 April 2008, respectively.

The Land Acquisition Collector had determined the market value at ₹16,00,000 per acre by award dated 21 October 2008.

The landowners relied on an earlier acquisition in the same village pursuant to the notification dated 29 September 2005, for which the Supreme Court had ultimately fixed the market value at ₹33,00,000 per acre by order dated 18 November 2025.

They claimed a 12% annual escalation for the 25-month interval between the two notifications and sought determination of the market value on that basis.

The State and HSIIDC contended that the earlier award should not be mechanically followed and that the market value should instead be determined from sale deeds produced before the Reference Court.

Whether the market value of the acquired land could be determined by relying on the Supreme Court’s valuation in the previous acquisition of adjoining land situated in the same revenue estate?

Whether escalation should be granted for the period between the earlier notification dated 29 September 2005 and the present notification dated 11 December 2007, and whether such escalation should be compounded?

Whether the sale deeds relied upon by the State or the additional sale deed dated 24 November 2005 justified a different determination of market value?

Whether the appellants were entitled to enhancement of compensation and all statutory benefits under the Land Acquisition Act, 1894?

The Court exercised appellate jurisdiction under Section 54 of the Land Acquisition Act, 1894, in relation to compensation determined under Sections 4, 6 and 18 of that Act.

A previous award or judgment is relevant evidence for determining market value but is not automatically binding; its comparability, the nature and location of the land, the evidence underlying it, and the extent and potentiality of the property must be independently examined, as held in Manoj Kumar v. State of Haryana, 2018(2) RCR (Civil) 815.

The Court relied on Ram Kishan (Since Deceased) through his LRs v. State of Haryana, 2025 SCC OnLine SC 715, for the principle that a previous award cannot be outrightly ignored merely because sale deeds are available and may be considered as a comparable exemplar where the lands are similar.

The Court also applied the recognised doctrine of presumptive escalation in land prices at approximately 10–12% per annum and treated 12% annual escalation as appropriate in the circumstances.

The Supreme Court’s earlier determination of ₹33,00,000 per acre for the adjoining acquisition in Village Rewasan, after appropriate deductions for distance, potentiality and the nature of the exemplars, was treated as the relevant base valuation.

The Court found that both acquisitions concerned land in Village Rewasan and that the land acquired under the earlier notification was adjoining or contiguous to the land involved in the present appeals.

Although the earlier award was not treated as mechanically binding, it was considered highly persuasive because the Supreme Court had independently assessed the market value of land in the same revenue estate at ₹33,00,000 per acre after considering the relevant sale exemplars and making appropriate deductions.

The purpose of the present acquisition—construction of a toll plaza and connecting highways—also demonstrated substantial development potential comparable to the earlier acquisition for the Kundli-Manesar-Palwal Expressway.

The State’s sale deeds disclosed values lower than the Collector’s award and therefore did not provide a reliable basis for reducing compensation.

The additional sale deed dated 24 November 2005 was rejected because it concerned developed industrial land in another village and was materially different from the acquired agricultural land.

For the 25-month interval between the two notifications, the Court applied a cumulative 24% escalation, treating the period as approximately two years and declining the landowners’ request for compound escalation.

Accordingly, ₹33,00,000 per acre was increased by 24%, resulting in a market value of ₹40,92,000 per acre.

The Court enhanced the market value of the acquired land from ₹16,00,000 to ₹40,92,000 per acre, calculated by applying a cumulative 24% escalation to the Supreme Court’s earlier valuation of ₹33,00,000 per acre for the adjoining acquisition in the same revenue estate.

The appellants were held entitled to all statutory benefits available under the Land Acquisition Act, 1894.

Any delay in filing the appeals was condoned by consent, but no interest was payable for the delayed period.

Pending applications were disposed of.