Comparable-sales valuation for acquired land requires deductions, plotted-area adjustments, and evidence close to the notification date.

For large land acquisitions, sale instances of small plots are not a safe guide unless they are proximate in time to the notification, bona fide, relate to the acquired or adjoining land, and possess similar advantages. Even then, deductions and other adjustments may be required, and market value must reflect what a willing purchaser would pay a willing vendor on the Section 4(1) notification date under the Land Acquisition Act, 1894. The Court approved comparable-sales valuation with necessary deductions and a plotted-area basis, and found no material to justify a substantial further increase on the record, though the appellants received limited enhancement on reassessment.

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Issues: Determination of market value for acquired large tracts of land by reference to sale instances of smaller plots, and the extent to which deductions and plotted-area calculations may be applied.

Analysis: For large acquisitions, sale prices of small plots are not a safe guide unless the sales are within a reasonable time of the notification, bona fide, relate to the acquired land or adjacent land, and have similar advantages. Even then, appropriate deductions and adjustments may be necessary. Market value must be determined on the basis of the price a willing purchaser would pay to a willing vendor, while ignoring compulsion on either side. The relevant statutory framework under the Land Acquisition Act, 1894 requires the Court to consider market value as on the date of the Section 4(1) notification, exclude irrelevant matters, and ensure that compensation does not fall below the Collector's award. Applying these principles, the Court accepted the use of comparable instances with adjustments, approved the adoption of plotted area, and found no basis for a substantial further increase on the record available.

Conclusion: The market value was rightly determined by applying comparable-sales methodology with necessary deductions and plotted-area basis, but the appellants obtained a limited enhancement on the Court's reassessment.

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