Market value for fair rent must rest on comparable sales, not guideline value or valuation registers alone.

Guideline value maintained by revenue authorities for stamp duty purposes cannot, by itself, be used to fix fair rent under rent control law. Market value must be determined from bona fide comparable sales, surrounding market evidence, or other recognised valuation methods, because guideline entries and valuation registers have no statutory force as proof of true market value. Sale deeds of comparable properties are the appropriate material for assessment, and reliance solely on guideline value is unsustainable for fixation of fair rent.

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Issues: Whether guideline value or valuation register maintained by revenue authorities can be treated as the basis for determining market value for fixation of fair rent under the rent control law.

Analysis: The proper method for ascertaining market value is not the guideline value prepared for collection of stamp duty, but evidence of bona fide transactions between willing purchasers and willing sellers, or other recognised valuation methods. The basic valuation register and municipal or revenue guideline entries have no statutory force as proof of market value and cannot be treated as the foundation for fixing fair rent. The better view is that sale deeds of comparable properties and surrounding market evidence are the relevant materials for determining true market value.

Conclusion: Guideline value could not be relied upon as the sole basis for fixation of fair rent, and the orders based on that approach were unsustainable.

Ratio Decidendi: For determining market value under the rent control law, guideline value maintained for stamp duty purposes has no evidentiary foundation by itself, and market value must be assessed on the basis of bona fide comparable sales or other recognised valuation methods.

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