2026 Supreme(Online)(P&H) 82474

IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH
Harkesh Manuja, J
Rajender Prasad – Appellant
Versus
State Of Harayana – Respondent
RFA-1872-2016

Previous judicial awards for land acquisition are relevant evidence to determine market value in subsequent cases if the lands are similar in potential, nature, and location, despite not being strictly binding as precedents.

Headnote:(A) Land Acquisition Act, 1894 - Section 4 and 18 - Determination of market value - Previous awards/judgments - Use of previous judgment as evidence - The court held that previous awards are relevant pieces of evidence and not binding precedents per se, but can be relied upon if the land is similar in nature, potential, and location - The appellant's land was similar in location and potential to land acquired three months earlier, for which a final market value was set. (Paras 13, 16.1)

Facts of the case:
The acquisition of land in Village Budhera, District Gurugram, was initiated via a Section 4 notification dated 19.08.2008 for a sewerage treatment plant. The Land Acquisition Collector assessed market value at Rs. 41,50,000/- per acre. The Reference Court enhanced this to Rs. 46,87,057/- per acre, against which the landowners filed these appeals seeking further enhancement based on a prior acquisition in the same village (notification dated 19.05.2008) which was valued at Rs. 2,80,00,000/- per acre.

Findings of Court:
The Court found that there was no significant difference in location or potential between the current acquisition and the previous acquisition (Moti Sagar case). Given the short 3-month temporal gap, the Court rejected the respondent's argument to ignore the previous award and instead relied upon the rate determined by this Court in the earlier matter as the best evidence of market value.

Issues: Whether previous judicial awards/judgments can be relied upon to determine market value in subsequent acquisitions under the Land Acquisition Act, and whether the appellants are entitled to the same market value as the prior acquisition.

Ratio Decidendi: While previous awards are not binding as precedents, they are relevant evidence. Where land similarity is proven and evidence of market value is lacking or unreliable, prior court-determined values for proximate and similar lands are the most reliable indicators of just compensation.

Result: Appeals partly allowed, market value enhanced to Rs. 2,80,00,000/- per acre with statutory benefits.