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04. After appreciating oral and documentary evidence, learned Reference Court has recorded the findings as under:

1. The reference is within limitation as notice under Section 12(2) of the LA Act was not duly served on the claimant.
2. The exemplar sale deeds of (Ex.P/14 and Ex.P/15) were found proximate in time and involving irrigated land in the same command area.
6. The market value was redetermined at Rs. 5, 66,611/- per acre based on Ex.P/14 and Ex.P/15.
7. The claimant has been found entitled to all statutory benefits under Sections 23(1-A), 23(2), and 28 of the Act.

05. The Learned Reference Court has found that the reliance of Land Acquisition Officer on rent-based average figures lacked correlation to actual market value and that no reliable exemplar was cited by the acquiring body. The exemplar sale deeds of Ex.P/14 and Ex.P/15 was NEUTRAL CITATION NO.2025:MPHC-IND:14117 F.A. No.226 of 2017 & Others found to be proximate in time, pertaining to irrigated land within the same command area, and genuinely executed. The learned Court held that Ex.P/14 and Ex.P/15 represented the best evidence of market value. Assessment charts Ex.P/7 and P/10 were rejected as they were derived from historical averages and lacked transparency.

8.3. Learned counsel further submitted that the learned Reference Court has committed a grave error in relying solely on sale deeds (Ex- P/14 & Ex-P/15) from Village - Jhundgav and Village - Kukravad of Tehsil - Harda which according to the appellants is not situated in proximity to the acquired land and was not shown to be similar in NEUTRAL CITATION NO.2025:MPHC-IND:14117 F.A. No.226 of 2017 & Others quality, location, access and potential. No evidence was led by the respondent to establish that the said land was comparable in all material respects to the acquired land before the L.A.O. In the absence of such comparability, the use of Ex.P/14 and Ex.P/15 as the sole benchmark by the court is incorrect. Learned counsel further submitted that the Court also failed to assess whether the said transaction was a bonafide transaction or an isolated sale involving exceptional circumstances or inflated consideration.

                                                       (i)     proximity from time angle,
                                                    (ii)     proximity from situation angle.

(11) Having identified the instances which provide the index of market value the price reflected therein may be taken as the norm and the market value of the land under acquisition may be deduced by making suitable adjustments for the plus and minus factors vis- à-vis land under acquisition by placing the two in juxtaposition. (12) A balance-sheet of plus and minus factors may be drawn for this purpose and the relevant factors may be evaluated in terms of price variation as a prudent purchaser would do. (13) The market value of the land under acquisition has thereafter to be deduced by loading the price reflected in the instance taken as norm for plus factors and unloading it for minus factors. (14) The exercise indicated in clauses (11) to (13) has to be undertaken in a common sense manner as a prudent man of the world of business would do. We may illustrate some such illustrative (not exhaustive) factors: