Nirmal Singh v. State of Haryana
Background
Agricultural land at Pehowa was acquired for roads and residential and commercial development. Owners sought higher compensation than the ₹9 lakh per acre fixed by the High Court. They relied on sales of nearby smaller plots and the acquired land's development potential.
Decision Breakdown
The Supreme Court increased compensation to ₹12 lakh per acre with statutory benefits and applicable interest. Small-plot sales could be considered because owners rarely have sales of comparably large tracts to produce. Their prices required substantial adjustment for development costs and differences in location and characteristics; the Court used a 60% development deduction in its assessment. Uncertainty about the precise location of the comparison plots also justified caution, and payment was directed within eight weeks.
Lesson Learnt
Owners can use genuine nearby small-plot sales to support a compensation claim for a larger acquisition. The final rate still depends on comparability and development costs; the highest nearby sale price is not automatically payable.