Land acquisition valuation must reflect Section 4 date and comparable local sales, not a mechanically low estimate

Land acquisition valuation is determined with reference to the Section 4 notification date, using genuine comparable sales from the locality and surrounding circumstances. The text notes that contemporaneous sale deeds and evidence of rising land prices may support a higher market value than an earlier lower valuation, and that acceptance of a nominal rate for other land does not control the present acquisition. On that basis, the acquired land is treated as entitled to enhanced compensation, with solatium and interest following the higher valuation.

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Issues: Whether the market value of the acquired land was correctly fixed and whether the appellant was entitled to enhanced compensation with consequential solatium and interest.

Analysis: The relevant date for valuation was the date of the notification under Section 4. The Court compared contemporaneous sale deeds from the same locality and rejected the approach of the courts below in treating the earlier valuation as decisive. It held that surrounding circumstances, location, and the rise in land prices in the locality showed that the acquired land had a higher market value than that fixed below. The Court also found that the appellant's later acceptance of a nominal rate for other land did not justify maintaining the lower valuation for the present acquisition.

Conclusion: The market value was held to be higher than that fixed by the courts below, and the appellant was entitled to enhanced compensation, solatium, and interest.

Final Conclusion: The award was modified by enhancing the compensation payable to the appellant, with proportionate costs and interest on the enhanced amount.

Ratio Decidendi: In land acquisition matters, the market value must be determined with reference to the notification date by relying on genuine comparable sales from the locality and surrounding circumstances, and not by mechanically adhering to a lower valuation unsupported by the evidence.

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