Land acquisition compensation must rest on recognised valuation evidence, not a stamp duty valuation register.

SC held that compensation for acquired land under the Land Acquisition Act must be determined on legally recognised valuation evidence, such as bona fide comparable sales, expert opinion, or actual or prospective income. A Basic Valuation Register maintained for stamp duty purposes has no statutory foundation as a binding yardstick for market value and cannot replace the settled evidentiary rules for land acquisition compensation. Section 47-A of the Indian Stamp Act, as locally amended, authorises reference to the Collector for valuation of the instrument presented for registration, but does not permit use of an administratively prepared valuation register as the basis for fixing market value of acquired land. The register could not be relied on to enhance compensation.

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Issues: Whether the Basic Valuation Register maintained for stamp duty purposes can be treated as evidence or a foundation for determining the market value of acquired land under the Land Acquisition Act.

Analysis: The determination of compensation under the Land Acquisition Act must rest on recognized methods of valuation, principally bona fide comparable sales, expert opinion, or evidence of actual or prospective income. Section 47-A of the Indian Stamp Act, 1899, as locally amended, permits reference to the Collector for determining market value in relation to the particular instrument presented for registration, but it does not confer any express statutory power to maintain a general Basic Valuation Register for an area and use it as a binding yardstick. A valuation register prepared for registration and stamp duty purposes has no statutory foundation for fixing market value of acquired land under Section 23(1) of the Land Acquisition Act. In the absence of reliable evidence of comparable sales or other legally acceptable material, such register cannot displace the settled evidentiary rules governing land acquisition compensation.

Conclusion: The Basic Valuation Register cannot be relied upon to enhance the market value of the acquired land, and the appellant was not entitled to compensation on that basis.

Ratio Decidendi: A valuation register prepared administratively for stamp duty purposes, without statutory foundation, is not admissible as the basis for determining market value under the Land Acquisition Act; compensation must be fixed on legally recognized evidence of market value.

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