Saraswatabai Motiram Tayade v. Vidarbha Irrigation Development Corporation
Background
The appellant-landowners' land, including 42 orange trees, was compulsorily acquired for an irrigation project. A reference court awarded compensation using a 15-year purchase multiplier for the orange trees, but the Bombay High Court's Nagpur Bench reduced this to a 10-year multiplier on appeal by the Vidarbha Irrigation Development Corporation, relying on general Supreme Court precedents about typical multipliers for plantations. The landowners appealed, pointing out that other landowners whose adjoining land was acquired under the very same acquisition notification had been awarded the higher 15-year multiplier, which the High Court had itself affirmed in an earlier, separate appeal that the Corporation had accepted without challenge.
Decision Breakdown
The Supreme Court held that the precedents relied on by the High Court to reduce the multiplier were not binding rules but were "facts and circumstances" specific to those cases, and did not override the strong evidentiary record here, including expert testimony that orange trees can bear fruit for 15-20 years. Since the Corporation itself had already accepted a 15-year multiplier for neighbouring landowners under the identical acquisition, and no valid reason was given for treating these appellants differently, the Court held that similarly situated landowners cannot be discriminated against in compensation. It restored the reference court's 15-year multiplier and directed payment of the balance amount with interest.
Lesson Learnt
When land is acquired from multiple owners under the same notification, courts must ensure consistent compensation principles are applied to all of them: a landowner cannot be given a worse deal than their neighbour for the same category of loss without a specific justified reason.