Development deduction for acquired land upheld where small-plot sale deeds were used to value a large undeveloped tract.

Valuation of acquired land for a housing scheme may require a substantial development deduction when compensation is based on sale deeds for very small plots. The Court held that such small-extents sales cannot be treated as the sole benchmark for a large, undeveloped tract, because the size disparity and the need for development justify reduction in the market value. Applying that principle, the High Court's 40% deduction was found consistent with settled compensation methodology and did not warrant interference. The compensation assessment was therefore upheld.

---

---

Issues: Whether the High Court was right in deducting 40% from the market value while fixing compensation for acquired land, having regard to the use of sale deeds relating to very small extents and the need for deduction towards development.

Analysis: The land was acquired for a housing scheme, and the valuation relied upon sale deeds of very small plots. The Court held that when small extents are used as comparables for valuing a large tract, a substantial deduction is necessary to account for developmental requirements and the disparity between the size of the sold plots and the acquired land. The Court considered the deduction made by the High Court to be consistent with the principle that such sales cannot be the sole basis for valuing large undeveloped lands, and referred to prior decisions supporting substantial deductions in appropriate cases.

Conclusion: The deduction of 40% did not call for interference and the compensation determination was upheld.

---