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Issues: (i) Whether the Reference Court and the High Court erred in determining compensation by relying mainly on oral evidence and earlier awards while ignoring sale deeds produced in evidence; (ii) Whether interference was warranted in exercise of discretionary jurisdiction despite the legal error in valuation.
Issue (i): Whether the Reference Court and the High Court erred in determining compensation by relying mainly on oral evidence and earlier awards while ignoring sale deeds produced in evidence.
Analysis: For fixing market value of acquired land, comparable sale instances are the best evidence where genuine, proximate in time, and relating to similar land in the vicinity. Where such direct evidence exists, the court must consider it and cannot proceed solely on oral testimony or stray prior awards. If the court departs from the valuation adopted by the acquiring authority, it must assign cogent reasons and assess the surrounding statutory factors relevant to compensation.
Conclusion: The Reference Court and the High Court were not justified in ignoring the sale deeds and relying principally on oral evidence and earlier awards; the valuation approach was legally flawed.
Issue (ii): Whether interference was warranted in exercise of discretionary jurisdiction despite the legal error in valuation.
Analysis: Even where an error of law is noticed, superior courts may decline interference in a case involving small monetary stakes and where disturbing the award would prolong litigation disproportionately. Discretionary relief is not to be granted as of right merely because the impugned decision is legally vulnerable, and equitable considerations may justify refusal of interference.
Conclusion: Interference was declined in the exercise of discretionary jurisdiction.
Final Conclusion: The appeals failed, and the impugned awards were allowed to stand notwithstanding the Court's disagreement with the reasoning on valuation.
Ratio Decidendi: Comparable sale deeds are the primary guide for land-acquisition compensation, but appellate interference may still be refused on equitable and discretionary grounds even where the valuation reasoning is erroneous.