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Ved & Anr. v. State of Haryana & Anr.

Civil Appeal · 2021 INSC 234Decided 8 Apr 2021
Civil Appeal No. 1158 of 2021
Justice Uday Umesh Lalit · Justice Vineet Saran

Background

Land in several villages (Nawada Fatehpur, Naurangpur, Manesar, Lakhnoula, Naharpur Kasan, Shikohpur) was acquired in 2004 by the Haryana State Industrial Development Corporation for Phase-V of the Industrial Model Township, Manesar, Gurgaon. The Land Acquisition Collector initially fixed compensation at Rs. 12.50 lakhs per acre; on reference, courts raised it, and the Punjab & Haryana High Court finally fixed Rs. 48.46 lakhs per acre (for land abutting the highway) and Rs. 43.61 lakhs per acre (for interior land). The landholders, dissatisfied with these rates, appealed to the Supreme Court seeking further enhancement.

Decision Breakdown

The Supreme Court reviewed the sale deeds relied upon by the High Court and found its reasoning for rejecting a higher-value sale deed (Exhibit P-20, which actually covered built-up industrial property, not bare land) to be correct. It also rejected the landholders' argument for a "cumulative annual increase" method based on a related judgment (Wazir v. State of Haryana), noting that the Court had earlier cautioned against extrapolating value increases over long gaps using only one method when direct sale-deed evidence was available and reliable. Finding no error in the High Court's valuation exercise, the Court dismissed all the appeals, leaving the High Court's compensation rates undisturbed.

Lesson Learnt

In land acquisition compensation disputes, courts give primacy to genuine, comparable sale-deed evidence over formula-based escalation methods, and a sale deed that bundles buildings/machinery with land is not reliable evidence of pure land value.

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

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