Prior awards may determine land-acquisition market value where contiguous lands share the same acquisition purpose and circumstances.

The appellants were landowners whose lands in Villages Sunaria Kalan and Myana, Tehsil and District Rohtak, were acquired under notifications dated 2 December 2010 under Section 4 and 21 July 2011 under Section 6 of the Land Acquisition Act, 1894, for construction of roads in Sectors 22, 22A, 22B and 22C, Rohtak.

The Land Acquisition Collector awarded compensation at ₹36,00,000 per acre by award dated 26 April 2012.

On references under Section 18, the Reference Court enhanced the market value to ₹44,24,000 per acre for Village Sunaria Kalan and ₹37,80,000 per acre for Village Myana.

The landowners appealed under Section 54 of the 1894 Act, relying principally on higher-value sale exemplars and a subsequent decision of the High Court in Dilbag v. State of Haryana, which had assessed land in Village Sunaria Kalan at ₹55,93,000 per acre.

Whether the market value of the acquired land should be enhanced from the rates determined by the Reference Court and fixed at ₹55,93,000 per acre on parity with the High Court’s decision in Dilbag?

Whether the sale deeds relied upon by the State could be disregarded merely because they disclosed values lower than the compensation awarded by the Collector?

Whether delay, if any, in filing the connected appeals was liable to be condoned and, if so, whether the appellants were entitled to interest for the delayed period?

The Court applied Sections 18 and 54 of the Land Acquisition Act, 1894, governing references against the Collector’s award and appeals to the High Court.

It relied on the principle that market value must be determined on the basis of the best available evidence, including comparable sale exemplars, while previous awards should neither be automatically rejected nor blindly followed; this principle was drawn from 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 further applied the rule in Lal Chand v. Union of India, (2009) 15 SCC 769, that sale deeds showing a lower market value cannot be ignored merely because the Collector awarded a higher amount; Section 25 only prevents the Reference Court from awarding compensation below the Collector’s award.

Comparable acquisitions involving contiguous land acquired for the same purpose may also support uniform valuation.

The Court found that the acquisitions in question, the earlier awards dated 26 April 2012, and the acquisition considered in Dilbag concerned geographically proximate land acquired for related sectoral-road purposes.

The State was unable to distinguish the present cases from Dilbag and had not appealed against the Reference Court’s reliance on the landowners’ sale exemplars.

Although the Reference Court had considered several sale deeds and applied a 75% deduction because the exemplar plots were small, the High Court held that the deduction was excessive.

Reducing the deduction to 70% produced a value of ₹53,08,500 per acre, which supported adopting the higher benchmark of ₹55,93,000 per acre fixed in Dilbag.

For Village Myana, the Court corrected the Reference Court’s computation of the sale deed dated 31 December 2007: the consideration of ₹94,50,000 related to 1 acre, 6 kanals and 17 marlas, yielding approximately ₹50,90,909 per acre, not ₹94,50,000 per acre.

Applying permissible escalation up to the December 2010 notification date resulted in a value of not less than ₹55,93,000 per acre.

The Court also clarified that the State’s sale deeds could not be excluded solely under Section 25, though the higher and more reliable exemplars justified the enhanced valuation.

The market value of the acquired land was directed to be determined at ₹55,93,000 per acre, in parity with the valuation in Dilbag v. State of Haryana.

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

Pending miscellaneous applications, if any, were disposed of.