Land acquisition compensation cannot be enhanced using stamp duty valuation circulars; market value must rest on comparable evidence.

Market value for land acquisition compensation must be determined with reference to the date of the Section 4(1) notification, and the claimant must show that exemplar lands are comparable in potential and advantageous features. A Government circular fixing value for registration or stamp duty is only a fiscal measure and is not relevant evidence for assessing market value under Section 23(1) of the Land Acquisition Act, 1894. In the absence of independent evidence supporting a higher valuation, the claim for further enhancement of compensation was rejected.

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Issues: Whether the compensation for acquired land could be further enhanced on the basis of a Government circular fixing market value for stamp duty purposes, and whether such circular could be treated as relevant evidence for determining market value under the Land Acquisition Act.

Analysis: The market value for acquisition has to be assessed with reference to the date of the notification under Section 4(1) of the Land Acquisition Act, 1894, and the claimant must establish that the acquired land and relied-upon exemplar lands possess similar potentialities or advantageous features. A circular issued for fixation of value for registration or stamp duty is a fiscal measure and has no relevance for determining market value under Section 23(1) of the Land Acquisition Act, 1894. In the absence of independent evidence supporting a higher valuation, the enhancement claimed could not be sustained.

Conclusion: The claim for further enhancement of compensation was rejected.

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