Summary
Landowners seeking enhanced compensation for Phase V of the Manesar industrial township failed to displace the High Court’s valuation based on comparable sale deeds. A transaction conveying an industrial plant, buildings and machinery was not a reliable bare-land exemplar. Cumulative escalation from earlier acquisition rates could not supplant reliable contemporaneous sales merely because it yielded a higher figure. With no State or acquiring-body appeal, the existing compensation was left intact.
Issues
- Whether comparable sales or cumulative annual escalation justified further enhancement of the acquired lands’ market value.
Held
- Only the landholders appealed. The scope was therefore whether enhancement was warranted, not reduction at the instance of the State or acquiring body, neither of which had appealed. (¶ 3)
- Exhibit P-20 included industrial buildings, structures and embedded machinery with the land. The Reference Court correctly rejected its composite consideration as an indication of bare-land market value. The High Court properly assessed the location, extent and features of the other exemplars. (¶¶ 2(D), 7-9)
- The earlier acquisition assessment relied upon by the High Court had subsequently been reduced in Wazir. Even so, the Court separately examined whether the landholders’ evidence supported enhancement and found no reason to interfere. (¶¶ 4, 8-9)
- Annual escalation from earlier nearby transactions or acquisitions is ordinarily a fallback where contemporaneous comparable evidence is unavailable and requires caution, especially over longer intervals. Wazir’s selection of the highest of the methods considered there did not require cumulative escalation to replace the sale-deed valuation in this case. (¶ 10-11)
Result
Landholders’ appeals dismissed without costs. High Court compensation of Rs48,46,000 per acre for Naurangpur and Lakhnoula and Rs43,61,400 per acre for Nawada Fatehpur, Naharpur Kasan and Shikohpur, with the ordered statutory benefits and individual interest conditions, left undisturbed.