Land acquisition compensation must rest on reliable comparable sales and proof that the award is inadequate

In land acquisition valuation, enhancement of compensation must be based on reliable comparable sales and other acceptable evidence showing that the award is inadequate. The claimants bear the burden of proving entitlement to higher compensation, and that burden is not discharged by reliance on non-comparable or unreliable sale instances, especially where the acquired lands are agricultural and lack developed amenities. The assessment of market value involves judgment, and appellate interference is not justified unless there is misapplication of principle. On the facts noted, the High Court was right in restoring the Land Acquisition Officer's award and refusing enhancement.

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Issues: Whether the High Court was justified in restoring the Land Acquisition Officer's award and refusing enhancement of compensation for the acquired lands on the basis of the sale instances and other evidence relied on by the claimants.

Analysis: The compensation dispute arose from acquisitions of agricultural lands in three villages. The Reference Court had enhanced compensation on the strength of sale deeds and other materials, but the evidence showed that the acquired lands were agricultural, lacked developed amenities, and were not shown to be comparable with the developed lands or small plots relied upon by the claimants. The burden lay on the claimants to establish inadequacy of the award and entitlement to enhancement, and that burden was not discharged by reliable comparable sales or acceptable legal evidence. The sale instances adopted by the Land Acquisition Officer were proximate in time and location, while the Reference Court's reliance on unreliable or non-comparable materials was unsupported. In such valuation matters, some element of judgment is inevitable, and interference is not warranted unless there is misapplication of principle.

Conclusion: The claimants were not entitled to enhancement, and the High Court was right in restoring the award of the Land Acquisition Officer.

Ratio Decidendi: In land acquisition matters, enhancement of compensation must rest on reliable comparable evidence, and the initial burden lies on the claimant to prove that the award is inadequate; absent such proof, appellate interference with the assessed market value is unwarranted.

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