Rfa No. 974 of 2024 · Punjab And Haryana At Chandigarh High Court · 2026
Case at a glance
Provisions considered
- Land Acquisition Act, 1894 ss. 4, 6
Key paragraphs
- Para 1313. Accordingly, the market value is assessed at a uniform rate of Rs. 35,99,960/- per acre on the date of notification under Section 4 of the 1894 Act in case(s) in hand as per the calculation below:- Calculation:- Sale deed dated Base Price =
- Para 1717. Pending misc. application(s), if any, shall also stand disposed of.
- Para 2929. In these extenuating circumstances, there exists significant disparity among the sale exemplars presently under consideration. Amongst these sale exemplars, being Ex. P2- P8 and Ex. P10, the highest sale instance values the land at Rupees 1,81,33,867 per acre, whereas the lowest values it at…
Judgment
this Court consolidated various precedents to affirm that in circumstances where there are multiple sale deeds available for consideration, the Court shall rely on the highest valued exemplars unless the prices fall within a narrow range, in which case calculating an average of the values therein may be more congruous.
In these extenuating circumstances, there exists significant disparity among the sale exemplars presently under consideration. Amongst these sale exemplars, being Ex. P2- P8 and Ex. P10, the highest sale instance values the land at Rupees 1,81,33,867 per acre, whereas the lowest values it at Rupees 16,94,000 per acre. Given this wide range and in light of the judicial precedents cited above, we are of the opinion that we should rely upon the highest sale exemplar, which is Ex. P5, rather than solely depending upon an average of the multiple sale deeds produced before us. Despite the Respondents’ vehement contention that Ex. P5 should not be relied upon owing to it being a significantly smaller parcel of land— the detailed analysis conducted above indicates no reason why Ex. P5 cannot be utilised to determine the amount of compensation to be awarded to the Appellants for the acquired land.” In view of the discussion made hereinabove, the sale deed Ex.PZ dated 25.05.2007 vide which 32 kanals 5 marlas of land was sold for a total sale consideration of Rs.1,93,49,760/- with base price of Rs.47,99,941/- per acre, being the best suitable exemplar needs to be relied upon for the purpose of determination of market value in the case(s) in hand.
Further, a perusal of the site plan Ex. P23 produced on record by the appellants/landowners shows that the entire acquired SANJAY GUPTA 2026.05.18 18:43 I attest to the accuracy and integrity of this document RFA-974-2024 (O&M) and other connected cases [7] land is situated in close proximity to National Highway No. 10 leading from Rohtak to Delhi and, as such, possessed significant locational advantage and potential for being developed for residential, commercial, and institutional purposes. It was also admitted by RW1 Suresh Kumar, Patwari, Office of the LAC, Rohtak, that the acquired land abuts the abadi of Village Kheri Sadh. In such circumstances, having regard to the purpose of acquisition, namely, “for development of Sector 27 A-B, Rohtak for public and semi-public use”, a deduction of 25% towards the development cost would suffice in the case(s) in hand.
The total area acquired from the revenue estate of Village Kharawar is 25.68 acres, whereas the land parcel forming part of sale instance Ex. PZ dated 25.05.2007 measures 32 Kanals 5 Marlas (i.e., slightly above 4 acres). In such circumstances, the difference in area is not so significant so as to warrant any deduction on account of the smallness of the transaction reflected in the same instance Ex.PZ.
Pertinently, the LAC, at the time of assessing the market value of the revenue estate of Village Kharawar, determined the same at the uniform rate of Rs.16,00,000/- per acre which clearly indicates that the respondent authorities were conscious of the fact that the land parcels of the acquired did not suffer from any material variation in terms of their locational advantage, accessibility, and development potential. Such assessment itself reflects that the entire acquired land formed part of a homogeneous tract possessing similar SANJAY GUPTA 2026.05.18 18:43 I attest to the accuracy and integrity of this document RFA-974-2024 (O&M) and other connected cases [8] characteristics and potentialities, warranting uniform treatment in the matter of valuation. In view of the aforesaid, the appellants/ landowners are held entitled to uniform market value, without adoption of any belting system.
Accordingly, the market value is assessed at a uniform rate of Rs. 35,99,960/- per acre on the date of notification under Section 4 of the 1894 Act in case(s) in hand as per the calculation below:- Calculation:- Sale deed dated Base Price =
25.05.2007 (Ex.PZ) Rs. 47,99,941/- per acre Deduction 25% 47,99,941 - 11,99,985.25 account of development (Price – 25% of Price) = 35,99,955.75 Net Value Rs. 35,99,960/- (rounded off)
In addition, the appellants/landowners shall also be entitled to all other statutory benefits and interest under the 1894 Act, especially solatium and interest thereupon.
In view of the aforesaid circumstances, the present appeals preferred at the instance of landowners are partly allowed with the aforesaid modification.
Further, wherever, landowner(s) has/have unfortunately expired in the appeal(s)/ cross-objection(s) after filing thereof and the legal heirs have not been impleaded, they shall be at SANJAY GUPTA 2026.05.18 18:43 I attest to the accuracy and integrity of this document RFA-974-2024 (O&M) and other connected cases [9] liberty to seek execution of the present decision by moving appropriate application(s) before the learned Executing Court.
Pending misc. application(s), if any, shall also stand disposed of.
12.05.2026 sanjay ( HARKESH MANUJA ) JUDGE Sr. No. Case No. 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. RFA-757-2022 (O&M) RFA-762-2022 (O&M) RFA-1730-2023 (O&M) RFA-1731-2023 (O&M) RFA-1195-2024 (O&M) RFA-2360-2016 (O&M) RFA-2502-2016 (O&M) RFA-2503-2016 (O&M) RFA-2504-2016 (O&M) RFA-2967-2016 (O&M)
12.05.2026 sanjay ( HARKESH MANUJA ) JUDGE SANJAY GUPTA 2026.05.18 18:43 I attest to the accuracy and integrity of this document
Questions this judgment answers
Which statutory provisions did this judgment involve?
Land Acquisition Act, 1894 — ss. 4, 6.
Which court decided this case, and when?
Punjab & Haryana High Court, on 12 May 2026. The bench was HARKESH MANUJA.
Precedent status how later indexed judgments have treated this case
No known negative treatment found in the Courts & Cases corpus.
This is a result about the indexed corpus, not a finding that the judgment remains good law. Coverage may be incomplete.