Land acquisition compensation enhancement justified by location, potentiality and comparable sale evidence

Compensation for acquired land was found liable to enhancement where the land's location, urban and commercial potential, and comparable sale material justified a higher market value. The Court noted that the High Court had relied on a solitary sale instance, but it also considered earlier valuation accepted in connected acquisition litigation, applied a 12% annual increase and a one-third deduction, and fixed a revised market value for the notification year. On that basis, the enhancement was upheld and the landowners were held entitled to the revised compensation.

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Issues: Whether the compensation awarded for the acquired land required enhancement on the basis of the land's location, potentiality and comparable sale evidence.

Analysis: The acquired land was notified under Section 4 of the Land Acquisition Act, 1894 and the compensation had been determined by the Reference Court after categorising the land and granting statutory benefits. The Court found that the High Court had relied on a solitary sale instance and, applying the earlier valuation accepted in connected acquisition litigation together with a 12% annual increase and a deduction of one-third, arrived at a revised market value for the year of notification. The Court treated the land as having significant urban and commercial potential and considered the enhancement to be justified.

Conclusion: The compensation was liable to be enhanced, and the appellants were entitled to the revised market value fixed by the Court.

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