Cumulative escalation in land acquisition compensation must be applied consistently; unequal rates and incomplete evidence led to remand.

Where market value for acquired land is derived from an earlier comparable transaction, escalation must be applied cumulatively over the time gap, not as a flat annual rate. The compensation assessment was found unsustainable because similarly situated landowners were given unequal escalation rates without a rational basis, and relevant sale and allotment evidence was not consistently applied. The compensation determination was therefore set aside and the matters remitted for fresh disposal, with directions for interim payment of the balance amount as ordered.

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Issues: Whether the compensation awarded by the High Court for the acquired land required interference because of unequal escalation rates, non-application of the cumulative increase method, and omission to properly consider relevant evidence, warranting remand for fresh determination.

Analysis: The compensation for the later acquisitions had been fixed by taking the earlier market value as the base, but the High Court applied different annual increase rates to similarly situated landowners without a discernible basis. The correct approach to escalation over a time gap is to apply the increase cumulatively, not as a flat rate. Relevant sale and allotment material, including the evidence relied upon for comparable land, was not fully and consistently applied in determining the market value. These errors affected the uniformity and soundness of the compensation assessment.

Conclusion: The compensation determination could not be sustained in its existing form. The appeals were allowed, the impugned judgment was set aside, and the matters were remitted for fresh disposal, with directions for interim payment of the balance amount as ordered.

Ratio Decidendi: Where market value is determined by escalation from an earlier comparable transaction, the increase must be applied cumulatively and not at a flat rate, and similarly situated landowners cannot be treated differently without a rational basis.

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