Land acquisition valuation requires genuine comparables; a Lok Adalat settlement alone is not a reliable basis for compensation.

Market value under the Land Acquisition Act, 1894 must be assessed by reference to the acquired land's nature, quality, location, potentiality, advantages and disadvantages, and comparable material must relate to lands shown to be similar in relevant respects. A Lok Adalat settlement fixing value of other lands, without particulars of the land covered or evidence of similarity in location and attributes, cannot by itself provide a reliable basis for enhancing compensation. The proper approach is to apply settled valuation principles and rely only on legally relevant material for the acquired land. On that basis, the settlement was not treated as a safe or proper guide, and the High Court's valuation was upheld.

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Issues: Whether a Lok Adalat settlement fixing market value of other lands could be treated as the basis for determining compensation for the acquired lands in the absence of proof that the lands were similarly situated.

Analysis: The determination of market value under the Land Acquisition Act, 1894 depends upon the nature, quality, location, potentiality, advantages and disadvantages of the acquired land, and comparable material must relate to lands shown to be similar in relevant respects. A settlement recorded in a Lok Adalat, without particulars of the land covered by it and without evidence showing similarity in location, nature and attributes, cannot by itself furnish a reliable basis for enhancement of compensation. The proper approach is to apply the settled principles governing valuation and to assess the acquired land on the material legally relevant to it.

Conclusion: The Lok Adalat settlement was not a safe or proper basis for fixing compensation, and the High Court's valuation was upheld.

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