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Issues: Whether the compensation for acquired land should be determined on the basis of comparable sale deeds and the claimant's own sale deed, or on the basis of stamp-duty valuation and other extraneous market references.
Analysis: Market value under the Land Acquisition Act is to be assessed primarily with reference to comparable sale instances of similar land. A valuation adopted by the registering authority for stamp duty purposes cannot be treated as the basis for market value. Where the claimant's own sale deed shows a much lower price, Section 92 of the Evidence Act, 1872 bars the claimant from asserting a contrary price for the same transaction. On the evidence, the relevant sale instances showed a value in the region of Rs. 15.37 to Rs. 15.40 per sq. yard. In view of the proved development potential of the locality, an increase on that base was justified, but the increase had to be applied to the correct sale price and for the correct time gap.
Conclusion: The compensation fixed by the High Court and the Reference Court was set aside and the market value was fixed at Rs. 24.64 per sq. yard, with entitlement to solatium and other statutory benefits under the Land Acquisition Act, 1894.
Ratio Decidendi: Market value for land acquisition must be determined on the basis of genuine comparable sale deeds, not stamp-duty valuation entries, and a party is bound by the price stated in its own registered sale deed.