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of <h1>SC Clarifies Land Acquisition Act: Certified Sale Copies Accepted as Evidence, Case Sent Back for Further Review.</h1> <h3>Cement Corporation Of India Ltd. Etc. Versus Purya And Ors. Etc.</h3> Cement Corporation Of India Ltd. Etc. Versus Purya And Ors. Etc. - 2004 AIR 4830, 2004 (8) SCC 270, 2004 (8) JT 327, 2004 (8) SCALE 558 Issues Involved:1. Interpretation of Section 51A of the Land Acquisition Act, 1894.2. Admissibility and evidentiary value of certified copies of sale transactions.3. Judicial discretion in accepting evidence.Summary:1. Interpretation of Section 51A of the Land Acquisition Act, 1894:The Supreme Court noticed a conflict between two 3-Judge Benches regarding the interpretation of Section 51A of the Land Acquisition Act, 1894. In *Kurra Sambasiva Rao* (1997), the Court held that Section 51A only facilitates the production of a certified copy of a sale transaction and does not make its contents admissible in evidence unless duly proved by examining the vendor or vendee. Conversely, in *V. Narasaiah* (2001), the Court held that Section 51A allows the certified copy of a sale transaction to be accepted as evidence without the need to examine the vendor or vendee.2. Admissibility and evidentiary value of certified copies of sale transactions:The Court in *Kurra Sambasiva Rao* interpreted Section 51A narrowly, stating that the marking of certified copies does not make the contents admissible unless proved by witnesses. However, in *V. Narasaiah*, the Court expanded the scope, stating that the legislative intent was to accept certified copies as evidence of the transactions, considering practical difficulties in examining parties to the sale. The Court highlighted that certified copies could be admitted as secondary evidence under Sections 64 and 65(f) of the Evidence Act and Section 57(5) of the Registration Act.3. Judicial discretion in accepting evidence:The Supreme Court concluded that the interpretation in *V. Narasaiah* was correct, allowing certified copies to be accepted as evidence without examining the vendor or vendee. However, it emphasized that the acceptance of such evidence is discretionary and must be judicially exercised. The Court clarified that the contents of a certified copy do not automatically prove the transaction but must be weighed with other evidence on record.Case Specifics:In C.A. No. 6986 of 1999, the Reference Court initially awarded compensation based on certified copies of sale transactions but did not consider other relevant evidence. The High Court enhanced the compensation solely based on the certified copies, which the Supreme Court found incorrect. The Supreme Court remanded the case to the High Court for a comprehensive evaluation of all evidence, including the comparative nature of the land, location, and market potentiality.Conclusion:The Supreme Court settled the interpretation of Section 51A, affirming *V. Narasaiah* as the correct law. It emphasized that while certified copies of sale transactions may be accepted as evidence, their contents must be judicially evaluated with other available evidence. The case was remanded to the High Court for reconsideration in line with these principles. Other connected appeals were directed to be placed before an appropriate Bench for final disposal.
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