No Evidence for Higher Value: Punjab & Haryana HC Dismisses Landowners' Appeal for Increased Compensation (Land Acquisition Act, 1894) - 2025-05-16

Punjab & Haryana High Court Upholds Rs. 2 Lakh/Acre Compensation, Cites Lack of Evidence from Landowners

Chandigarh: The Punjab and Haryana High Court, in a common order dated July 9, 2018, dismissed a batch of Regular First Appeals (RFAs) filed by landowners from Village Satloda, District Hisar, who sought enhanced compensation for land acquired by the State of Haryana. The bench, presided over by Justice Rekha Mittal , found no grounds to increase the market value beyond the Rs. 2,00,000 per acre determined by the Reference Court, primarily due to the appellants' failure to produce evidence supporting a higher valuation.

Case Background: A Decade-Long Quest for Higher Compensation

The dispute traces back to a notification issued on May 10, 2002, under Section 4 of the Land Acquisition Act, 1894, for acquiring land for the construction of the Satloda Minor Drain. This was followed by a declaration under Section 6 of the Act on July 8, 2002, proposing to acquire land from two villages, Satloda and Barsana , in District Hisar.

The Land Acquisition Collector (LAC) initially offered compensation at the rate of Rs. 1,00,000 per acre on July 11, 2002. Dissatisfied landowners sought a reference, and the Reference Court, by an award dated June 11, 2007, enhanced the market value to Rs. 2,00,000 per acre. Still seeking further enhancement, several landowners, including Subhash Chander and others (in RFA No. 327 of 2013 and connected matters), approached the High Court. This judgment specifically pertains to appeals arising from Village Satloda.

Arguments Before the High Court

The primary contention of the appellants (landowners) was that the market value of their acquired land was significantly higher than the Rs. 2,00,000 per acre awarded by the Reference Court.

However, a crucial point emerged during the High Court proceedings. As noted in the judgment, "Learned counsel representing the appellants very fairly admits that the landowners have not produced any sale instance to prove that the market value of the acquired land was more than Rs.2,00,000/- per acre."

The State of Haryana, on the other hand, had not filed any appeal challenging the Reference Court's enhancement to Rs. 2,00,000 per acre, indicating its acceptance of this valuation.

Court's Reasoning: No Scope for Further Increase Without Evidence

Justice Rekha Mittal , in her ruling, emphasized the lack of evidentiary support for the landowners' claim for a higher market value. The Court observed that the present appeals were solely related to land acquired in Village Satloda.

The judgment stated: > "Learned counsel representing the appellants very fairly admits that the landowners have not produced any sale instance to prove that the market value of the acquired land was more than Rs.2,00,000/- per acre."

Given this admission and the fact that the State had not contested the Rs. 2,00,000 per acre figure, the Court found no basis for further enhancement.

The Court concluded: > "Keeping in view the aforesaid facts, there is no scope for further increase in the market value of the acquired land assessed by the [Reference Court]. Hence, all the appeals are dismissed." (Note: While the judgment text at one point mistakenly says "Land Acquisition Collector" when referring to the Rs. 2,00,000 assessment, the context clearly indicates the Reference Court's award was under review).

Final Decision and Implications

The High Court dismissed all the appeals filed by the landowners from Village Satloda. Consequently, the compensation for their acquired land remains at Rs. 2,00,000 per acre as determined by the Reference Court, along with other statutory benefits. Any pending miscellaneous applications in these appeals were also disposed of.

This decision underscores the critical importance for claimants in land acquisition cases to substantiate their claims for enhanced compensation with concrete evidence, such as comparable sale instances, to demonstrate a higher prevailing market value. Without such proof, courts are unlikely to interfere with valuations determined by lower forums, especially when counsel concedes the absence of supporting evidence.