Certified sale deeds as evidence under land acquisition law can support market value without witness examination

Certified copies of registered sale deeds may be treated as evidence of the transactions recorded in them under Section 51A of the Land Acquisition Act, 1894, without examining the vendors, vendees, or other connected witnesses. The provision was enacted to remove practical difficulty in proving comparable sales, but the court must still assess the documents' probative value in light of surrounding circumstances and any rebuttal evidence. Such certified copies are therefore admissible for determining market value of acquired land, provided the court is satisfied that they are reliable and relevant comparable sales.

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Issues: Whether certified copies of registered sale deeds could be treated as evidence of the recorded transactions under Section 51A of the Land Acquisition Act, 1894 without examining persons connected with those transactions, and whether such sale deeds could be relied upon for determining the market value of acquired land.

Analysis: Section 51A was introduced to meet the practical difficulty of proving comparable sales by examining vendors, vendees, or other persons connected with the transaction. The provision enables the court to accept a certified copy of a registered document as evidence of the transaction recorded in it. This does not make the evidence conclusive or compulsorily reliable; the court must still assess its weight along with the surrounding circumstances and any rebuttal evidence. The earlier view that the document could not be looked into unless a connected witness was examined was not accepted. Comparable sale deeds, therefore, can be considered for fixing market value even if no witness to the transaction is examined, so long as the court is satisfied about their probative value.

Conclusion: Certified copies of registered sale deeds are admissible under Section 51A as evidence of the recorded transactions, and the High Court was justified in relying on them for determining market value despite the absence of witnesses to those transactions.

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