Market value in land acquisition claims may be fixed by recent bona fide sale of the same land, barring special circumstances.

Compensation under the Land Acquisition Act was required to be assessed by reference to market value on the date of the section 4(1) notification, and a bona fide recent sale of the same land was treated as the best indicator where it reflected normal market conditions. Because the claimant had purchased the identical land about ten months before acquisition at a much lower price, and no special circumstance justified disregarding that transaction, the court found no basis to displace that valuation. Comparable nearby sales did not show any material error in the High Court's assessment, and interference in a compensation appeal was held unwarranted absent a wrong principle or material omission. Further enhancement was refused and the High Court's compensation award stood.

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Issues: Whether the claimant was entitled to further enhancement of compensation for land acquired under the Land Acquisition Act, 1894, by displacing the market value fixed on the basis of his own recent purchase and comparable sales.

Analysis: Compensation under section 23 is to be determined by reference to the market value on the date of the section 4(1) notification. The most reliable indicator of value is a bona fide recent transaction of the same land, provided it reflects normal market conditions. Here, the claimant had purchased the identical land only about ten months before acquisition at a much lower price, and no special circumstance was proved to justify ignoring that sale. Comparable neighbourhood sales also did not show any clear error in the High Court's assessment. In an appeal against compensation, interference is warranted only where the award is vitiated by a wrong principle or material omission, not merely because another view is possible.

Conclusion: The claim for further enhancement was rejected and the compensation fixed by the High Court was left undisturbed.

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