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Issues: (i) Whether the market value of acquired land could be determined on the basis of Ready Reckoner rates and the Government Resolution relied upon by the High Court.
Analysis: The binding decisions governing compensation under the Land Acquisition Act held that valuation for acquisition must be made on recognised evidence of market value, such as bona fide sale instances and other admissible material, and not on uniform valuation meant for stamp duty. Ready Reckoner rates are prepared for collection of stamp duty and registration charges for an area as a whole, and do not account for the specific location, size, frontage, development, and other relevant advantages or disadvantages of the acquired land. In view of Article 141 of the Constitution of India, the High Court could not ignore the binding law and base enhancement of compensation solely on the Ready Reckoner or the Government Resolution.
Conclusion: The Ready Reckoner rates could not form the basis for determining compensation, and the High Court erred in enhancing compensation on that footing.
Final Conclusion: The award of the Reference Court was restored and the appeal succeeded.
Ratio Decidendi: Valuation prepared for stamp duty purposes cannot, by itself, be treated as the basis for determining market value under the land acquisition law; compensation must be fixed on legally admissible evidence of market value relevant to the acquired property.