Jurisdiction in land acquisition compensation depends on a valid reference, and valuation stands where comparable sales support the rate adopted.

In land acquisition proceedings, the civil court can determine compensation only when a valid statutory reference on that issue has been made; a reference confined to apportionment does not confer jurisdiction to decide quantum, and the absence of such reference is an inherent defect that cannot be waived. On valuation, the court found the rejected sale instances too remote, insufficiently comparable, or otherwise unreliable, while the accepted sales and the agricultural nature of the lands with road proximity supported the rate adopted. The compensation figure was therefore upheld and left undisturbed.

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Issues: (i) Whether the court had jurisdiction to determine the amount of compensation in the absence of a reference under the land acquisition law. (ii) Whether the compensation fixed by the High Court called for interference on the sale-deed evidence.

Issue (i): Whether the court had jurisdiction to determine the amount of compensation in the absence of a reference under the land acquisition law.

Analysis: The statutory scheme made the award final except where a person interested, by written application, required a reference to the court. The court's power to decide objections arose only upon a valid reference by the Collector, and the scope of the proceedings was confined to the matters so referred. A reference limited to apportionment could not confer authority to decide quantum of compensation. Since no reference on compensation had been made on the applications objecting to the award, the defect went to the root of jurisdiction and could not be waived by failure to object earlier.

Conclusion: The court had no jurisdiction to determine compensation, and the objection of waiver failed.

Issue (ii): Whether the compensation fixed by the High Court called for interference on the sale-deed evidence.

Analysis: The sale instances rejected by the High Court were either too remote in time, insufficiently comparable in location, or otherwise unreliable on the facts. The accepted sales provided a reasonable basis for valuation, and the lands being agricultural lands with advantageous road proximity justified the rate adopted. No substantial ground was shown to disturb the valuation reached below.

Conclusion: The valuation did not call for interference.

Final Conclusion: The appeal failed both on jurisdiction and on merits, and the compensation determination was left undisturbed.

Ratio Decidendi: In land acquisition matters, the civil court acquires jurisdiction to determine compensation only upon a valid statutory reference, and absence of such reference is a defect of inherent jurisdiction that cannot be waived.

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