Comparable sale instances and recorded consideration govern land valuation; higher stamp duty alone cannot replace the sale price.

Where a proximate and comparable sale instance is available, older and less comparable sales should not be preferred for fixing market value; the 1991 sale deeds were therefore excluded in favour of the nearer 1994 transaction. A higher stamp duty payment did not justify replacing the consideration stated in the sale deed, because the recorded price must stand absent evidence of undervaluation, distress sale, or other proof that it was not the real price. For development deduction, the urban character, municipal location, road frontage, and surrounding amenities supported a 25% deduction rather than one-third, and the market value was accordingly reduced.

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Issues: (i) Whether the 1991 sale deeds could be relied upon for determining the market value when a more proximate sale deed of 1994 was available; (ii) whether payment of higher stamp duty than the consideration mentioned in the sale deed justified treating the higher value as the market price; (iii) whether the deduction towards development cost should be 25% or one-third.

Issue (i): Whether the 1991 sale deeds could be relied upon for determining the market value when a more proximate sale deed of 1994 was available.

Analysis: The 1979 acquisition relied upon in the earlier judgments was too remote in point of time to have any bearing on the market value of land acquired in 1994. The 1991 sale deeds were not rejected merely because they were three years old, but because they related to lands found to be far away from the acquired lands, whereas a nearby sale transaction of 1994 itself was available. In such circumstances, reliance on older and less comparable transactions was unwarranted.

Conclusion: The 1991 sale deeds were rightly excluded from consideration.

Issue (ii): Whether payment of higher stamp duty than the consideration mentioned in the sale deed justified treating the higher value as the market price.

Analysis: The consideration stated in a sale deed cannot be ignored merely because stamp duty was paid on a higher value. A higher stamp duty may be payable for several reasons, including application of guideline value. In the absence of evidence that the recorded consideration was not the real price, or that the transaction was under-valued or distress driven, the sale price in the document had to be accepted.

Conclusion: The higher stamp duty did not justify substituting a higher market value for the stated consideration.

Issue (iii): Whether the deduction towards development cost should be 25% or one-third.

Analysis: The acquired lands were within municipal limits, abutting a road, and situated in a developed urban area with nearby civic amenities. Having regard to these special features, the deduction adopted by the Reference Court was excessive. A smaller deduction was appropriate for arriving at the market value of a large tract from a small developed plot sale instance.

Conclusion: The deduction towards development cost was correctly fixed at 25%.

Final Conclusion: The market value was reduced, the claimants' challenge failed, and the statutory benefits awarded were left undisturbed.

Ratio Decidendi: Where a proximate and comparable sale instance is available, older and less comparable sales should not be preferred; the consideration stated in a sale deed cannot be displaced merely because stamp duty was assessed on a higher guideline value; and the deduction for development must reflect the urban character and comparable utility of the acquired land.

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