Plot-based land valuation and interest on withheld compensation upheld where development potential supported small-plot comparables.

Acquired land capable of development in plotted form may be valued on a plot basis by reference to comparable small-plot transactions, rather than as a single block, where the broader evidence supports that approach; the High Court's reduction was therefore unjustified and the District Judge's valuation was restored. Additional compensation that was withheld because of stay proceedings carried interest for the period of deprivation, as the claimant was wrongly kept out of the amount and was entitled to recompense for that loss. The appeals were thus partly allowed, with interest awarded at 6% per annum for the relevant period.

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Issues: (i) Whether the acquired land was to be valued on a plot basis or on a block basis, and whether the reduction made by the High Court was justified. (ii) Whether interest was payable on the additional compensation for the period during which payment was withheld.

Issue (i): Whether the acquired land was to be valued on a plot basis or on a block basis, and whether the reduction made by the High Court was justified.

Analysis: The compensation had to be assessed with reference to the most appropriate comparable sales and the factual layout of the land. The land was capable of being developed and sold in plots under the existing lay-out, and the evidence did not justify treating the property as a single block for valuation. A stray statement in cross-examination was insufficient to displace the broader evidence supporting plot-wise valuation. The comparable instances from the nearby Mahanager scheme furnished a proper basis for fixing the average rate.

Conclusion: The High Court's reduction was not justified. Valuation on a plot basis was proper, and the rate fixed by the District Judge was restored.

Issue (ii): Whether interest was payable on the additional compensation for the period during which payment was withheld.

Analysis: The additional compensation was available for withdrawal but was not paid because of the proceedings initiated to secure a stay and the consequent withholding of payment. In those circumstances, the claimant was entitled to interest on the amount ultimately restored, for the period of deprivation.

Conclusion: Interest was payable on the additional amount at 6 per cent per annum from 8 July 1948 to 12 May 1949.

Final Conclusion: The valuation adopted by the District Judge was substantially restored, and the claimant also obtained interest for the period during which the additional compensation was withheld, resulting in a partial allowance of the appeals.

Ratio Decidendi: Where acquired land is capable of development and sale in plotted form, valuation may properly be made on a plot basis by reference to comparable small-plot transactions, and interest on compensation is payable for the period during which the claimant is wrongly deprived of the amount.

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