Judicial review of Chapter XX-C valuation is limited to legality; High Court cannot reweigh comparable-sale material.

In judicial review of a Chapter XX-C compulsory purchase order, valuation based on comparable sales with appropriate deductions for tenancy was treated as a permissible method and not arbitrary merely because another method might also have been available. The Supreme Court reiterated that Article 226 review is limited to the legality of the decision-making process; the High Court cannot reappraise valuation material or substitute its own view where the statutory authority has adopted a reasonable method supported by reasons. The confirmed auction sale during the proceedings also weighed against disturbing the acquisition order, as setting it aside after the sale had attained finality would create an anomalous situation.

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Issues: (i) whether the Appropriate Authority's order for compulsory purchase under Chapter XX-C was liable to be interfered with on the ground that the valuation method adopted was wrong or arbitrary; (ii) whether the High Court could reappreciate the valuation material and substitute its own conclusion in exercise of writ jurisdiction; and (iii) whether the confirmed auction sale of the property during the pendency of proceedings affected the correctness of the High Court's interference.

Issue (i): whether the Appropriate Authority's order for compulsory purchase under Chapter XX-C was liable to be interfered with on the ground that the valuation method adopted was wrong or arbitrary.

Analysis: The valuation disclosed in the show-cause notice was based on comparable sales, with adjustments for location, tenancy, and other relevant features. The Court held that a tenanted property could still be valued by comparison with similar properties after making appropriate deductions for tenancy, and that the method adopted by the Department could not be branded illegal, irrational, or arbitrary merely because another method might also have been possible.

Conclusion: The challenge to the valuation method failed, and the Department's valuation-based action was sustained.

Issue (ii): whether the High Court could reappreciate the valuation material and substitute its own conclusion in exercise of writ jurisdiction.

Analysis: The Court reiterated that proceedings under Article 226 involve judicial review of the decision-making process, not an appellate review of the decision itself. Where two views are possible on the materials, the High Court cannot replace the conclusion of the statutory authority with its own. The High Court had gone into the correctness of the valuation as if sitting in appeal, which exceeded the permissible scope of review.

Conclusion: The High Court's interference on merits was unsustainable.

Issue (iii): whether the confirmed auction sale of the property during the pendency of proceedings affected the correctness of the High Court's interference.

Analysis: The Court noted that the auction had been permitted and later confirmed by the Court, the sale had been completed, and the original owner had accepted the consideration without protest. Setting aside the acquisition order after the sale had attained finality would create an anomalous situation and the High Court ought to have considered that consequence before disturbing the statutory order.

Conclusion: The confirmed auction sale reinforced the unsuitability of the High Court's interference.

Final Conclusion: The appeals succeeded, the High Court's judgment was set aside, and the order of the Appropriate Authority under Chapter XX-C was restored.

Ratio Decidendi: In judicial review of compulsory purchase under Chapter XX-C, the High Court may examine only the legality of the decision-making process and not reappraise valuation material or substitute its own assessment where the statutory authority has adopted a permissible valuation method supported by disclosed reasons.

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