Valuation must account for title defects and plot-size differences; failure to adjust comparable sales can vitiate the assessment.

Market value must be assessed by considering all factors affecting title and comparability, including absence of title deeds, a cloud on title, and any pending challenge to the release deed, because these circumstances can affect market perception and creditworthiness. A valuation based on sale of a smaller comparable plot is not reliable unless proper adjustment is made for differences in size, as smaller plots may command a higher rate and cannot be treated as directly comparable to larger land. The valuation order was therefore held unsustainable, set aside, and the matter was remanded for fresh decision in accordance with law after hearing the parties.

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Issues: Whether the authority's valuation order could be sustained when it ignored the effect of absence of title deeds, cloud on title, and the need for proper adjustment while relying on sale of a smaller comparable plot.

Analysis: The property valuation had to take into account that the title deed was unavailable, since that circumstance affects market perception and creditworthiness. The authority also failed to accord due weight to the pending challenge to title and the possibility of the release deed being questioned. In relying upon a smaller nearby plot as a comparable without making any adjustment for difference in size, the authority applied an approach inconsistent with settled principles governing valuation, because smaller plots may fetch a higher rate and larger plots cannot be assumed to command the same price without appropriate adjustment.

Conclusion: The valuation order was unsustainable and was set aside.

Final Conclusion: The matter was remanded to the authority for fresh decision in accordance with law after hearing the parties, and the writ petitions were allowed.

Ratio Decidendi: In determining market value, relevant factors affecting title and comparability of sales, including absence of title deeds and differences in plot size, must be properly considered and adjusted; failure to do so vitiates the valuation.

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