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Bhag Singh Etc. vs Union of India & Anr. Etc.

Civil Appeal · 2022 INSC 515Decided 5 May 2022
Civil Appeal Nos. 4076-4082 of 2012
Hemant Gupta · V. Ramasubramanian

Background

Land in Villages Sohana and Lakhnaur, Punjab, was acquired by the government under a 1990 notification, with compensation later fixed by the Reference Court at Rs. 4 lakhs per acre (based on an earlier, unchallenged award for the adjoining village land under the same notification). The land owners appealed to the High Court and then the Supreme Court, arguing they deserved much higher compensation, comparing their land to a different village (Kambali) where courts had awarded Rs. 5.96-8 lakhs per acre for other, later acquisitions. The High Court had dismissed both the land owners' and the Union's appeals, upholding the Rs. 4 lakh figure.

Decision Breakdown

The Supreme Court rejected the land owners' comparison to Village Kambali, holding that a physical layout plan and Survey of India maps showed Kambali was over 2 km away and not actually adjoining Sohana, unlike the neighbouring Village Mataur, so its higher compensation rates were not a valid yardstick. The Court also refused to import compensation rates fixed for a later (1993) acquisition notification, reasoning that price increases after a subsequent notification reflect development triggered by the earlier acquisitions themselves, not organic market appreciation applicable backward in time. Even calculating a notional 10% annual increase from an earlier 1981 valuation, the resulting figure stayed below what the High Court had already awarded. Finding no error in the High Court's reliance on the unappealed compensation award for the adjoining acquired land (Village Lakhnaur, part of the same notification), the Court dismissed all the appeals and affirmed Rs. 4 lakhs per acre.

Lesson Learnt

In land acquisition compensation cases, courts will only accept comparable-village or comparable-transaction evidence if genuine geographic proximity and timing are established: a citizen cannot claim a higher rate awarded for a distant or later-acquired plot without showing it is a truly comparable market benchmark.

Official source (sci.gov.in)View Judgment (PDF)

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