The Executive Engineer, M.I.W. v. Vitthal Damodar Patil & Anr.
Background
The government acquired agricultural land in Jalgaon, Maharashtra in 1998 for building a minor irrigation tank, and the landowners sought enhanced compensation for the land and the fruit-bearing trees on it, relying on a valuation report by a private valuer. The trial court (Reference Court) rejected that valuation and fixed a lower rate, but the Bombay High Court, relying on an earlier Supreme Court case that had accepted a report from the very same valuer, overturned that finding and enhanced the compensation significantly. The government (Executive Engineer) appealed to the Supreme Court, arguing the High Court had mechanically copied the outcome of the earlier unrelated case instead of independently examining the valuer's credibility and evidence in this specific case.
Decision Breakdown
The Supreme Court agreed with the government, holding that the High Court had misapplied the earlier precedent: that precedent only dealt with a different evidentiary issue (a discarded sale instance) and never examined the valuer's personal competence, qualifications, or the specific objections raised in cross-examination in this case. Because every land-acquisition reference must be decided on its own evidence, the mere fact that the same valuer's report was accepted in an unrelated proceeding could not substitute for the High Court actually analysing the detailed cross-examination and competency challenges raised here. The Court allowed the appeal, set aside the High Court's judgment, and sent the matter back to the High Court to decide the original appeal afresh on its own merits, keeping all arguments on both sides open.
Lesson Learnt
A court cannot resolve a factual dispute (such as the reliability of an expert witness's valuation) just by pointing to a different, unrelated case where the same expert's evidence was once accepted: each case must be decided on the specific evidence and cross-examination actually placed on its own record.