Comparable sale valuation permits development and time-gap deductions for undeveloped acquired land, with uniform compensation maintained.

Comparable-sale valuation of acquired land permitted deductions for development, roads, civic amenities, de-escalation and waiting period where the exemplar was a small developed site and the acquired tract was large undeveloped agricultural land. The 55 percent development deduction was within the permissible range, and the additional 10 percent de-escalation and 5 percent waiting-period deductions were supported by the time gap and settled escalation principles. The cumulative 70 percent deduction remained within the outer benchmark recognised in precedent, and uniformity with compensation fixed for similarly situated land justified the final rate of compensation.

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Issues: Whether the High Court was justified in reducing the compensation awarded by the Reference Court by applying deductions towards development, de-escalation and waiting period, and in fixing compensation at Rs. 65,000 per acre.

Analysis: The acquired land was large, undeveloped agricultural land, whereas the exemplar sale related to a small developed site. In determining market value on the basis of a comparable sale, appropriate deductions had to be made for land to be left out for roads, civic amenities and other infrastructure, as well as for the cost of development and related factors such as waiting period and de-escalation. On the facts, the High Court's deduction of 55 percent towards development was within the permissible range for a fully developed exemplar and an undeveloped acquired tract. The additional deductions of 10 percent for de-escalation and 5 percent for waiting period were also supported by the time gap between the notification and the sale deed and by the settled approach for land price escalation. The cumulative deduction of 70 percent remained within the outer benchmark recognised in precedent. The further fixation of compensation at Rs. 65,000 per acre was upheld in view of the need for uniformity with compensation already fixed for similarly situated land acquired under the same notification.

Conclusion: The deductions and the final compensation fixed by the High Court were upheld.

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