Summary
The Supreme Court replaced the High Court’s 15% cumulative annual escalation over eleven years with 8% cumulative escalation for valuing acquired land. With no usable contemporaneous exemplar, the earlier award supplied the base, but the long interval made a high uniform escalation unsafe. The Collector was directed to recalculate, recover any excess lawfully or pay any balance within two months of receipt of the judgment.
Issues
- What annual escalation fairly adjusted an earlier land valuation across an eleven-year interval.
- How payments already disbursed should be reconciled with the recalculated compensation.
Held
- The available sale deeds were unsuitable comparators for reasons the Court accepted. The earlier reference award concerning the same village therefore remained the valuation base. (¶ 14–15)
- Annual escalation depends on the facts, especially the time gap. A method reasonably reliable over a few years may become unsafe over a longer period because of changing growth rates, stagnation or sudden price increases. (¶ 17–23)
- The High Court’s 15% cumulative escalation for eleven years was unjustified on this record. Balancing fair compensation and the public exchequer, the Court selected 8% cumulative annual escalation. This was a case-specific assessment, not a universal tariff. (¶¶ 13, 23–25)
- The Collector was to compute the resulting compensation and adjust amounts already paid. Any excess was recoverable in accordance with law; any additional sum due to the owners was payable within two months of receipt of the judgment. (¶ 26–27)
Result
Appeals allowed; High Court judgment set aside. Compensation to be recalculated using 8% cumulative annual escalation over the eleven-year gap, with lawful recovery of excess or payment of the balance within two months of receipt. No costs.