Statutory valuation committee reports constitute expert evidence for determining market value absent comparable sale exemplars.

The State initiated acquisition of agricultural lands situated at Moje Nanikadi, Taluka Kadi, District Mehsana, for a public purpose. The notification under Section 4 of the Land Acquisition Act, 1894 was published on 28 April 2009. The Special Land Acquisition Officer determined compensation at ₹39 per square metre. The landowners sought references under Section 18, which were registered as L.A.R. Nos. 960 to 962 of 2013 before the Principal Senior Civil Judge, Kadi.

Before the Reference Court, the claimants relied principally on Exhibit 22, being the proceedings of the District Valuation Committee. The Committee had assessed the value of non-agricultural land in the locality at ₹600 per square metre as on 22 November 2006, considering the proximity of Nanikadi to Kadi town and surrounding urbanisation.

The Reference Court applied a 60% deduction—30% for conversion from non-agricultural to agricultural land and 30% for location/development factors—and arrived at ₹240 per square metre. Applying a 10% annual increase for the period between 22 November 2006 and 28 April 2009, it fixed the market value at ₹298 per square metre and awarded additional compensation of ₹259 per square metre over the original award, together with statutory benefits and interest.

The acquiring authority challenged the enhancement in the present appeals under Section 54 of the Land Acquisition Act, 1894 read with Section 96 of the Code of Civil Procedure, 1908.

Whether the Reference Court was justified in relying on the District Valuation Committee’s report at Exhibit 22, in the absence of direct registered sale exemplars, for determining the market value of the acquired agricultural land?

Whether the deductions applied by the Reference Court to the Committee’s non-agricultural valuation and the subsequent 10% annual escalation were legally and factually justified?

Whether an earlier judicial determination of ₹124 per square metre for land in the same village restricted the compensation in the present acquisition to approximately ₹200 per square metre?

The Court applied Section 54 of the Land Acquisition Act, 1894, governing appeals from awards in land-acquisition references, read with Section 96 of the Code of Civil Procedure, 1908.

For valuation, it relied on the principle that market value may be determined through relevant and reliable evidence other than sale exemplars, including the opinion of a statutorily constituted expert valuation committee.

Relying on State of Gujarat through Special Land Acquisition Officer v. Amaji Mohanji Thakore, 2010 (3) GLH 447, and Lal Chand v. Union of India, (2009) 15 SCC 769, the Court held that the assessment of an expert committee can constitute relevant evidence where prepared in accordance with the prescribed procedure, subject to rebuttal by contrary evidence.

The Court also relied on Special Land Acquisition Officer v. Nurjahan Amirali Sayyad, G.H.J. (2010) 25, for the permissibility of applying a 10% annual increase to account for the passage of time between the valuation date and the notification date.

The burden in the present evidentiary context was effectively assessed by considering whether the acquiring authority had produced contrary sale exemplars or other material capable of dislodging the Committee’s valuation.

The Court held that the absence of registered sale deeds did not render Exhibit 22 inadmissible or unreliable. The District Valuation Committee was a governmental expert body, and its assessment specifically considered the geographical proximity of Nanikadi to Kadi town, local urbanisation, and developmental potential.

Since the acquiring authority did not produce contrary sale transactions or other material to rebut the Committee’s valuation, the Reference Court was entitled to rely on Exhibit 22 as the valuation foundation.

The Court further found the 60% deduction reasonable and sufficiently conservative: ₹600 per square metre was reduced to ₹240 per square metre to account for the agricultural character of the land and its location relative to Kadi town.

The addition of ₹58 per square metre, representing a 10% annual increase over approximately two years and five months, was consistent with the applicable valuation principle and resulted in a market value of ₹298 per square metre.

The earlier rate of ₹124 per square metre did not control because it related to an earlier period, whereas the Committee’s assessment reflected intervening urbanisation and infrastructure development in the locality.

Finding no error, illegality, or perversity in the judgment and award dated 13 February 2014 in L.A.R. Nos. 960 to 962 of 2013, the Court dismissed First Appeal Nos. 172, 173 and 174 of 2016.

The enhanced compensation of ₹259 per square metre over and above the original rate of ₹39 per square metre, together with statutory benefits and interest, was consequently upheld.