Pre-emptive purchase valuation under Chapter XX-C is insulated from writ interference absent perversity, irrelevance, or manifest unreasonableness.

Chapter XX-C permits compulsory pre-emptive purchase where apparent consideration is found to be 15 per cent or more below fair market value, after notice, hearing, and comparison with relevant sales adjusted for time and location. The Delhi HC accepted the use of comparable instances from the same locality and recognised plus-minus adjustments as a rational valuation method. It also reaffirmed that judicial review under Article 226 is confined to the decision-making process and does not allow the court to reappraise an expert statutory valuation unless it is unsupported by evidence, based on irrelevant considerations, or manifestly unreasonable. On that basis, the challenge to the purchase order failed.

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Issues: Whether the order of compulsory pre-emptive purchase under Chapter XX-C was liable to be interfered with in writ jurisdiction on the ground that the apparent consideration was not shown to be 15 per cent. or more below fair market value, and whether the authority's valuation process was perverse or arbitrary.

Analysis: The statutory scheme permits pre-emptive purchase where the apparent consideration is found to be 15 per cent. or more below fair market value, after issuing notice, hearing the parties, and considering relevant comparable sales with suitable adjustments for time and location. The material relied upon by the authority included comparable instances in the same locality, and the court accepted the use of plus and minus factors as a recognised method of valuation. The court further held that judicial review under Article 226 is confined to the decision-making process and does not permit the High Court to sit in appeal over the valuation arrived at by an expert statutory authority unless the decision is based on no evidence, irrelevant considerations, or is manifestly unreasonable.

Conclusion: The purchase order was not shown to be perverse, unreasonable, or arbitrary, and the challenge to the pre-emptive purchase failed.

Ratio Decidendi: In writ jurisdiction, a pre-emptive purchase order under Chapter XX-C will not be interfered with if the statutory authority has relied on relevant comparable sales and adopted a rational valuation process, unless the decision is vitiated by perversity, irrelevance, or manifest unreasonableness.

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