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M/s Acquainted Realtors LLP etc. v. State of Haryana & Others

Civil Appeal · 2021 INSC 235Decided 8 Apr 2021
Civil Appeal Nos. 1330-1332 of 2021
Justice Uday Umesh Lalit · Justice Vineet Saran

Background

Land in villages Dhana, Kasan, Bas Huria, Bas Khusla and Bas Lambi was acquired in 2005-06 for Phase-VI (Transport Hub) of the Industrial Model Township, Manesar, Gurgaon. Over the years, different Reference Courts had awarded inconsistent compensation for essentially the same acquisition, ranging from about Rs. 46 lakhs to Rs. 68 lakhs per acre for different villages without clear justification for the differences. The Punjab & Haryana High Court, relying on a sale deed used in a related case for a neighbouring acquisition, fixed a uniform rate of Rs. 43.61 lakhs per acre for all the villages. The landholders appealed, seeking a higher rate.

Decision Breakdown

The Supreme Court rejected the landholders' argument based on a post-acquisition sale deed (which it found rightly excluded because it bundled industrial structures with land) and their claim for a 12% cumulative annual increase. However, it found two factors distinguishing this acquisition from the related case the High Court had relied on: the land here was closer to an under-construction expressway, and this acquisition occurred about a year later than the comparable one, which should logically carry some value appreciation that the High Court had not accounted for. Balancing this against the fact that the base valuation it was building on was itself already on the higher side, the Court granted the landholders a flat 8% increase over the High Court's rate, enhancing compensation to Rs. 47,10,500 per acre plus statutory benefits.

Lesson Learnt

Even where a court's base valuation method is broadly sound, specific distinguishing factors, such as proximity to new infrastructure or a time gap between notifications, can still justify a calibrated enhancement in land acquisition compensation, rather than either accepting or rejecting a claim wholesale.

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

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