Land acquisition valuation requires fresh market-value assessment using comparable sales, with no double deduction for development delay.

In a section 18 land acquisition reference, market value must be determined afresh on the basis of genuine comparable sale instances proved on the record, as on the section 4 notification date, with suitable adjustments for size, frontage, location and development potential. The Court approved a 25% deduction for largeness of the block and the fixation of the interior land at Rs. 7,000 per acre. It also held that a further present-value discount for a 12-year development wait was unwarranted where that delay had already been reflected in the valuation, because the same factor cannot be counted twice.

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Issues: (i) the proper method for determining compensation and market value of acquired land under a reference under section 18 of the Land Acquisition Act; (ii) whether, after valuing the interior land at Rs. 7,000 per acre, a further discount to ascertain present value on the footing of a 12-year wait for development was warranted.

Issue (i): the reference under section 18 is an original proceeding and not an appeal against the award of the Land Acquisition Officer; the Court must determine market value afresh on the material proved before it. Market value is to be assessed as on the date of publication of the section 4 notification, by reference to genuine and comparable instances, after identifying the most comparable sale instances and making suitable adjustments for plus and minus factors such as size, frontage, proximity to road, situation, and development potential.

Conclusion: the valuation must be made afresh on the basis of comparable genuine instances and appropriate developmental adjustments, and the High Court committed no error in applying a 25% deduction for largeness of block and in fixing the interior land at Rs. 7,000 per acre.

Issue (ii): once the land had already been valued at Rs. 7,000 per acre to account for its interior location and delayed development, a further reduction by discounting that figure as present value after 12 years was not justified. The estimated waiting period had already been reflected in the lower valuation, and applying an additional present-value deduction duplicated the same factor.

Conclusion: the further discounting was erroneous, and the appellant was entitled to compensation at Rs. 5,250 per acre after the 25% deduction for roads and open spaces.

Final Conclusion: the appeal succeeded to a limited extent by restoring a higher compensation figure for the acquired land, while leaving the remaining valuation methodology substantially intact.

Ratio Decidendi: In a land acquisition reference, market value must be determined independently on the basis of proved comparable instances as on the section 4 notification date, with adjustments for relevant location and development factors, but the same factor cannot be counted twice by making an additional present-value deduction after it has already been reflected in the valuation.

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