The 2.0 multiplier applies to rural land acquired for Railway projects, regardless of State acquisition.

The respondent’s land was acquired for construction of the Mahoba–Khajuraho section of the Lalitpur–Singrauli Railway Line Project. The Collector, by award dated 04.11.2019, assessed compensation at ₹17,70,620. On reference under the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 (“LARR Act”), the Reference Court enhanced the compensation to ₹37,37,480, resulting in a net enhancement of ₹19,66,860 after deducting the amount already awarded

The Railways appealed under Section 74 of the LARR Act, challenging the application of a multiplication factor of 2.0 and the Reference Court’s finding that the acquired land was irrigated.

The appeal was admitted and, with the parties’ consent, heard finally

Whether the Central Government’s multiplication factor of 2.0 for rural land applied where the acquisition was undertaken by the State Government but was for a Railway project of the Union Government?

Whether the Reference Court correctly treated the acquired land as irrigated on the basis of revenue records and evidence regarding irrigation through a borewell?

Section 26(2) of the LARR Act requires the market value of land to be multiplied by the factor specified in the First Schedule, while Section 3(e)(v) identifies the Central Government as the “appropriate Government” for acquisition of land for the purpose of the Union. The Central Government notification dated 09.02.2016, issued under Section 30(2) read with the First Schedule, prescribes a factor of 2.0 for rural areas

The Court relied on Badrilal Dhakad v. Union of India, 2022 SCC OnLine MP 280, and the coordinate Bench decision in F.A. No. 1373 of 2023, holding that the Central Government’s factor applies to land acquired for Central Government projects, including Railways, even where the acquisition is formally undertaken by the State Government

The Court also relied on Section 117 of the Madhya Pradesh Land Revenue Code, under which revenue entries carry a presumption of correctness until rebutted by contrary evidence

The Court held that the relevant consideration was the purpose for which the land was acquired, not merely the identity of the authority undertaking the acquisition. Since the land was acquired for a Railway project, it was acquired for the purpose of the Union within Section 3(e)(v) of the LARR Act; accordingly, the Central Government’s notification prescribing a rural multiplication factor of 2.0 applied

The Court noted that the earlier authorities had conclusively settled this issue and found no reason to take a different view. Unlike the facts considered in the precedent concerning buildings and other attached assets, the present acquisition involved only land; therefore, the factor of 2.0 was applicable to the entire compensation component in question

On the irrigation issue, the revenue khasra recorded the land as irrigated, and the Railways failed to rebut the statutory presumption of correctness under Section 117 of the Madhya Pradesh Land Revenue Code. In addition, the Reference Court had found that a borewell in Survey No. 266 irrigated the relevant sub-divisions, and that factual finding was not shown to be perverse

Finding no illegality or perversity in the Reference Court’s award, the Court dismissed First Appeal No. 1254 of 2025