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Issues: Whether circle rates meant for stamp duty could be treated as the basis for determining market value and compensation in land acquisition matters.
Analysis: Circle rates are prepared for the limited purpose of stamp duty and do not, by themselves, represent the actual market value of property. Market value may vary with the nature and situation of land and cannot be fixed on the basis of circle rates unless they are shown to have been determined by a statutory committee on a scientific and methodical assessment of market value. In the absence of such material, the High Court's reliance on circle rates was unsustainable.
Conclusion: Circle rates could not form the basis for determining compensation, and the impugned judgment was rightly set aside with the matter remitted for fresh decision.
Ratio Decidendi: Circle rates intended for stamp duty cannot be used as the sole basis for fixing land acquisition compensation unless they are shown to be the product of a statutory, scientific and methodical assessment of market value.