Pre-emptive purchase valuation must be property-specific, not based on mechanical comparison with dissimilar sale instances.

Under Chapter XX-C, market value for compulsory pre-emptive purchase must be fixed on fair, objective and property-specific criteria as on the date of the agreement. A large property with an existing structure cannot be valued mechanically by comparing it with a few smaller vacant sale instances, because size, location, structure, title uncertainties, marketability and the pool of potential purchasers materially affect value. The Authority's reliance on limited comparable sales and simple extrapolation, without independent evaluation of the relevant circumstances, was unsustainable and the purchase order was set aside, with the matter remitted for fresh valuation on proper criteria.

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Issues: Whether the order directing compulsory purchase of the property under Chapter XX-C was sustainable when the market value had been determined by comparing only a few smaller sale instances without an independent evaluation of the material circumstances affecting the subject property.

Analysis: The valuation adopted for pre-emptive purchase must be made with reference to the date of the agreement and by taking into account all relevant advantages and disadvantages then existing. A large property with an existing structure cannot be equated mechanically with smaller vacant plots sold earlier, because size, location, structure, title uncertainties, marketability, and the limited class of potential purchasers materially affect value. The Authority's order rested substantially on two earlier sale instances and a simple extrapolation, without demonstrating any independent application of objective criteria or specialised valuation analysis to the property in question.

Conclusion: The compulsory purchase order was unsustainable and was set aside. The matter was remitted to the Authority for a fresh determination of market value on acceptable and relevant criteria, taking into account all circumstances existing on the date of the agreement.

Ratio Decidendi: Under Chapter XX-C, market value for pre-emptive purchase must be determined on fair, objective, and property-specific criteria as on the date of the agreement, and a mechanical extrapolation from dissimilar sale instances is not a lawful basis for compulsory purchase.

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