VidhiSangh

Supreme Court of India · 28/07/2025

MANOHAR AND OTHERS versus THE STATE OF MAHARASHTRA & OTHERS

[2025] 7 S.C.R. 1675 · 2025 INSC 900

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Summary

Farmers whose land near Jintur was acquired in the 1990s for an MIDC industrial area challenged the compensation fixed by the Reference Court, which had averaged lower sale instances while ignoring, without reasons, the highest exemplar of Rs. 72,900 per acre (sale deed dated 31.03.1990); the High Court dismissed their first appeal on a self-contradictory finding that the exemplar had been considered. The Court held that when several exemplars of similar land exist the highest bona fide exemplar is ordinarily to be adopted, averaging is permissible only where prices fall within a narrow band, and certified copies of sale deeds carry presumptive value under Section 51A of the Land Acquisition Act; applying a 20 per cent deduction for the small size of the exemplar plots, it enhanced compensation to Rs. 58,320 per acre.

Issues

  1. Whether the High Court's finding that the Reference Court had considered the sale instance at Serial No. 4 (deed dated 31.03.1990) was sustainable.
  2. Whether the claimants were entitled to compensation on the basis of the highest exemplar sale deed rather than an average of lower sale instances.
  3. Whether the exemplar at Serial No. 4 could be excluded as abnormally high or as not proved to be a bona fide transaction.
  4. What deduction should be applied to exemplars of small plots when valuing a large acquired area.

Provisions considered

Held

Result

Appeals allowed; the High Court's judgment dated 21.04.2022 and the Reference Court's award dated 07.06.2007 quashed and set aside; compensation enhanced from Rs. 32,000 to Rs. 58,320 per acre, with all consequential benefits of solatium and interest under Sections 23(1-A), 23(2) and 28 of the Land Acquisition Act, 1894; pending applications disposed of.

Judgment PDF: Supreme Court of India, [2025] 7 S.C.R. 1675.