Land Acquisition Compensation: Supreme Court Dismisses Appeal for Higher Market Value

The legal battle in the case of Ved & Another vs. State of Haryana & Another centered around compensation for landowners whose lands were acquired for industrial development. The Supreme Court was tasked with determining whether the compensation set by the High Court for lands in various Haryana villages was fair or if the landowners deserved higher rates.

Background of the Case

The Haryana government initiated land acquisition proceedings in 2004 under the Land Acquisition Act, 1894 for setting up the Industrial Model Township (IMT), Manesar. The notification under Section 4 of the Act covered multiple villages, and the Land Acquisition Collector initially set the market rate at Rs. 12.50 lakhs per acre. Dissatisfied landowners challenged this valuation in the Reference Court, which revised it to approximately Rs. 50.43 lakhs per acre for most villages.

The acquiring body, Haryana State Industrial and Infrastructure Development Corporation (HSIIDC), appealed the decision, while some landowners sought further enhancement. The High Court recalibrated the compensation to Rs. 48.46 lakhs per acre for villages near National Highway-8 and Rs. 43.61 lakhs per acre for other villages.

Read also: https://judgmentlibrary.com/supreme-court-rules-on-land-compensation-dispute-in-haryana-key-takeaways/

Petitioners’ Arguments

The landowners sought higher compensation, arguing:

• The lands had high commercial and industrial potential, given their proximity to Gurgaon.
• Sale deeds of nearby lands suggested much higher values, some exceeding Rs. 1 crore per acre.
• Using past land valuation from adjacent acquisitions, an annual increase should be applied to adjust compensation.

Respondents’ Arguments

The Haryana government and HSIIDC contended:

• The High Court had already applied an appropriate escalation based on evidence.
• Comparing compensation with distant or commercially developed plots was misleading.
• Applying an arbitrary annual increase beyond a reasonable period would inflate the land’s market value.

Supreme Court’s Findings

The Supreme Court, comprising Justices Uday Umesh Lalit and Vineet Saran, upheld the High Court’s ruling, noting:

• Market valuation must rely on concrete sale transactions and not mere speculative increases.
• The Exhibit P-20 sale deed, cited by landowners, was rightly discarded as it included industrial buildings and machinery, not just land.
• The High Court’s compensation assessment was already at the higher end and did not warrant further revision.

Judgment and Conclusion

The Supreme Court ruled:

“In the circumstances, the decision of the High Court which is presently under appeal calls for no interference and these appeals are dismissed.”

This verdict reinforces the principle that land acquisition compensation must be based on transparent valuation methods rather than speculative projections. The ruling provides clarity on the judicial approach towards fair compensation in large-scale land acquisitions.

Read also: https://judgmentlibrary.com/supreme-court-dismisses-appeal-in-business-debt-dispute-case/

Petitioner Name: Ved & Another.
Respondent Name: State of Haryana & Another.
Judgment By: Justice Uday Umesh Lalit, Justice Vineet Saran.
Place Of Incident: Haryana.
Judgment Date: 08-04-2021.

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