Uniform compensation rates apply to contiguous lands acquired under common notifications for a common purpose.

The appeals under Section 54 of the Land Acquisition Act, 1894 challenged the award dated 28.10.2025 passed by the Additional District Judge, Sonepat, concerning acquisition of land in ten villages, including Kundal, for development of an Industrial Modern Township.

The Section 4 notification was issued on 01.04.2010 and the Section 6 notification on 04.04.2011. The Land Acquisition Collector assessed the market value at ₹30,00,000 per acre by award dated 01.04.2013.

On reference, the Reference Court enhanced the compensation to ₹42,00,000 per acre for land situated up to five acres from the PWD road and ₹37,00,000 per acre for the remaining land.

The landowners sought further enhancement, while HSIIDC challenged the enhancement. The parties relied upon earlier decisions of the High Court, affirmed by the Supreme Court, fixing the market value for similarly situated land acquired under the same notifications at ₹37,00,000 per acre, with an additional ₹5,00,000 per acre for land abutting the road.

Whether the market value of the acquired land in Village Kundal required determination at a rate different from the rate fixed by the Reference Court for similarly situated villages acquired under the same notifications and for the same public purpose.

Whether the sale deed relied upon by the landowners, relating to a small parcel of 1 Kanal 2 Marlas and indicating a higher per-acre price, justified further enhancement of compensation for the acquisition of approximately 815.81 acres in Village Kundal.

Whether the appeals filed by the landowners and HSIIDC against the Reference Court’s award deserved interference.

The Court applied Section 54 of the Land Acquisition Act, 1894, governing appeals against awards in land-acquisition references, along with Sections 4, 6 and 18 concerning notification, declaration and reference proceedings.

The Court applied the principle that market value must ordinarily be assessed with reference to the date of the Section 4 notification, which was 01.04.2010.

It further applied the rule that where lands in different villages are contiguous, similarly situated, acquired through common notifications for a common purpose, and possess comparable potential, a uniform market value may be awarded absent strong distinguishing circumstances.

This principle was drawn from HSIIDC v. Pran Sukh & Others, 2010 (11) SCC 175, Ali Mohammad Beigh & Others v. State of J&K, 2017 (4) SCC 717, Union of India v. Bal Ram, 2010 (5) SCC 747, and Union of India v. Harinder Pal Singh & Others, 2005 (12) SCC 564.

The Court also applied the evidentiary principle that a small isolated sale instance cannot, without appropriate adjustments and corroboration, determine the value of a large tract acquired for a common development project.

The Court held that the acquisition covered 3,300 acres across ten villages for the same industrial-development project and that the acquired lands formed a contiguous and substantially comparable tract.

In earlier decisions concerning other villages covered by the same notifications, the Court had fixed the market value at ₹37,00,000 per acre, with an additional ₹5,00,000 per acre for land abutting the highway or PWD road; those determinations had been upheld by the Supreme Court.

Applying the principle of uniform valuation for similarly situated lands, the Court found no justification to assign Village Kundal a different rate.

The landowners’ reliance on a sale deed showing a price of ₹1,56,18,181 per acre was rejected because it related to only 1 Kanal 2 Marlas, whereas approximately 815.81 acres in Village Kundal had been acquired and the total acquisition covered 3,300 acres.

Moreover, the evidence relied upon had already been considered in the earlier connected decisions.

Consequently, the Reference Court’s valuation was found consistent with the binding and persuasive precedent governing the same acquisition.

It upheld the Reference Court’s assessment of ₹42,00,000 per acre for land up to five acres from the PWD road and ₹37,00,000 per acre for the remaining land.

The appeals filed by both the landowners and HSIIDC were dismissed, and the Reference Court’s award dated 28.10.2025 was affirmed.

Any delay in filing the appeals was condoned by consent, but the landowners were denied interest for the delayed period.

Pending applications were also disposed of.