Certified sale deeds are admissible evidence under land acquisition law, but market value must still be fixed on all relevant material.

Section 51A of the Land Acquisition Act, 1894 is an enabling evidentiary provision: a certified copy of a registered sale deed may be received as evidence of the transaction without examining the vendor or vendee, but it does not create a mandatory or conclusive presumption as to the truth of its contents. The document's probative value remains open to judicial appraisal and may be rebutted by other evidence. In compensation ination, market value cannot be fixed by relying only on certified copies of sale deeds; comparable sales, location, potentiality and all other relevant material must be weighed together before arriving at compensation.

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Issues: (i) Whether Section 51A of the Land Acquisition Act, 1894 makes a certified copy of a registered sale deed admissible as evidence of the transaction without examining the vendor or vendee and whether it creates a mandatory or conclusive presumption as to the truth of the contents; (ii) whether, while determining compensation under the land acquisition law, the court may rely solely on certified copies of sale deeds without considering other relevant evidence bearing on market value.

Issue (i): Whether Section 51A of the Land Acquisition Act, 1894 makes a certified copy of a registered sale deed admissible as evidence of the transaction without examining the vendor or vendee and whether it creates a mandatory or conclusive presumption as to the truth of the contents.

Analysis: The statutory setting showed that certified copies were already admissible under the Evidence Act and the Registration Act, and Section 51A was introduced to remove practical difficulties in producing original sale deeds and examining the parties to the transaction. The words used in Section 51A permit the court to accept the certified copy as evidence of the transaction, but the provision is enabling and discretionary, not mandatory. Acceptance of the document as evidence does not automatically prove its truth or render the contents conclusive; at most, the document may carry a rebuttable presumption of genuineness which can be displaced by other evidence.

Conclusion: Section 51A permits admissibility of certified copies of sale deeds as evidence of the transaction without the need to examine the vendor or vendee, but it does not create a conclusive presumption or compel the court to accept the contents as proved.

Issue (ii): Whether, while determining compensation under the land acquisition law, the court may rely solely on certified copies of sale deeds without considering other relevant evidence bearing on market value.

Analysis: The valuation exercise requires appreciation of all relevant material, including comparable sales, location, potentiality, suitability, and other circumstances affecting market value. A certified copy admitted under Section 51A is only one piece of evidence and must be weighed with the rest of the record. An arithmetical fixation of compensation on the basis of the sale deed figures alone, without a comparative examination of the evidence, is not a proper approach.

Conclusion: The court cannot determine market value by relying only on the certified copies; they must be assessed along with the other evidence on record.

Final Conclusion: The legal position was settled in favour of treating certified copies of sale deeds as admissible evidence of the recorded transaction, but not as conclusive proof of contents, and the matter in the lead appeal was remanded for reconsideration on the correct evidentiary approach while the remaining connected matters were directed to be placed before an appropriate Bench.

Ratio Decidendi: Section 51A of the Land Acquisition Act, 1894 is an enabling evidentiary provision that allows certified copies of registered sale deeds to be received as evidence of the transaction, but the probative value of such material remains subject to judicial appraisal with the aid of other evidence.

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