Land acquisition valuation permits comparable sales averaging with freehold, auction, and development adjustments; statutory interest and proportionate costs stand.

Comparable sale instances may be used to assess acquired land value when they are genuine, proximate in time, and from the same locality, and an average may be taken where the instances fall within a narrow range. Leasehold exemplars may be adjusted upward for freehold status, while auction prices may require deduction for competitive bidding and planned development of a large tract. Statutory interest is payable only under the distinct provisions governing original and enhanced compensation, and no further interest is due where both components have already been granted. Costs may be apportioned in line with partial success, and proportionate costs are a proper exercise of discretion.

---

---

Issues: (i) Whether dismissal of the earlier special leave petition filed by the acquiring authority barred the landowners' appeals on maintainability; (ii) whether the market value of the acquired land was correctly determined on the basis of comparable leasehold sale instances, with appropriate adjustments for freehold status, competitive bidding, and development deductions; (iii) whether the landowners were entitled to any further interest over and above that already awarded; and (iv) whether the award of proportionate costs called for interference.

Issue (i): Whether dismissal of the earlier special leave petition filed by the acquiring authority barred the landowners' appeals on maintainability.

Analysis: Dismissal of the special leave petition with reasons operated only against the acquiring authority. It did not prevent the landowners from pursuing their separate challenge, particularly when their review proceedings were still pending at the relevant time.

Conclusion: The appeals were maintainable and not barred by the earlier dismissal of the special leave petition.

Issue (ii): Whether the market value of the acquired land was correctly determined on the basis of comparable leasehold sale instances, with appropriate adjustments for freehold status, competitive bidding, and development deductions.

Analysis: Comparable sales from the same locality and proximate in time can form a valid basis for valuation, and where several genuine instances show only a narrow range, averaging is permissible. The leasehold exemplars were capable of comparison, though an addition was required to account for the higher value of freehold land. Since the exemplars were auctioned plots, a deduction for competitive bidding was also justified. For a large acquired tract requiring planned development, deductions towards land reserved for amenities and development expenditure were necessary, and the total deduction adopted by the High Court was not shown to be perverse or excessive.

Conclusion: The compensation fixed by the High Court was sustained, and no further enhancement was warranted.

Issue (iii): Whether the landowners were entitled to any further interest over and above that already awarded.

Analysis: Interest under the land acquisition statute is payable under the distinct statutory provisions governing original compensation and enhanced compensation. The record showed that both statutory interest on the base award and interest on the enhanced amount had already been granted.

Conclusion: No further relief on interest was payable.

Issue (iv): Whether the award of proportionate costs called for interference.

Analysis: Costs under the land acquisition statute are discretionary and may be apportioned having regard to the extent of success. As the claim had succeeded only partly, proportionate costs were a proper exercise of discretion.

Conclusion: The award of proportionate costs was upheld.

Final Conclusion: The landowners' challenge failed on all substantial grounds, and the compensation, interest, and costs as fixed below were left undisturbed.

Ratio Decidendi: In land acquisition matters, comparable sales may be averaged when they are genuine, proximate, and broadly similar; valuation must then be adjusted for differences such as freehold status, auction-induced price inflation, and development requirements, while statutory interest and costs are governed by the express land acquisition provisions and the court's discretion on the facts.

---