The judgment covers 27 connected appeals concerning land acquisition by the State of Haryana.

The Supreme Court grouped the appeals into two categories:

1. 11 appeals related to lands acquired in Malpura & Kapriwas (2010 notification).

2. 16 appeals concerned Dharuhera lands acquired in 2008 – the main issue in this case.

The 16 appeals pertained to village Dharuhera, acquired via a notification dated 12.12.2008 under Section 4 of the Land Acquisition Act, 1894.

The acquisition was for Institutional Sector 5A under HUDA (Haryana Urban Development Authority).

Initial LAC award: ₹21,00,000 per acre.

Landowners demanded: ₹2,00,00,000 per acre.

Landowners filed reference petitions under Section 18 of the Act.

They argued that Dharuhera had:

Been declared a Municipal Committee Town (2007)

Developed sectors, commercial establishments, schools, and proximity to    RIICO Industrial Complex,      Bhiwadi.

Sector roads and multistorey buildings already built.

Sale deeds showed rates between ₹1 crore to ₹1.80 crore per acre in 2006–07.

Site map (Exhibit PW6/1) showed land’s proximity to key institutions and NH-8.

Reference to Malpura acquisition (2010 notification) where:

   Sale deed dated 13.08.2008 showed ₹1.42 crore per acre.

   Court applied 60% development deduction and fixed rate at ₹67,12,050/acre.

Although Malpura acquisition happened later (2010), the Reference Court used it for comparison.

Applied 12% reverse deduction for 17 months → ₹55,71,010 per acre awarded for Dharuhera.

High Court dismissed appeals and confirmed ₹55.71 lakh per acre.

Ignored comparable sale exemplars like PW4/E, PW4/F, PW4/H, which had higher prices.

Relied on only one lower-value sale deed (PW4/D).

In BESCO Ltd. v. State of Haryana (2023), SC enhanced compensation for Malpura/Kapriwas (2010 notification) from ₹1.21 crore to ₹1.49 crore/acre.

Basis: Sale deed of ₹1.42 crore/acre, lesser deduction (33% instead of 60%), and strong location factors.

Appellants in Dharuhera sought parity with BESCO, as both locations were only 5 km apart.

Same purpose: urban sector development.

High Court rejected claim, wrongly stating the lands weren’t comparable.

CLU permission.

Located along NH-8.

Industrial and residential development within 1 km.

SC confirmed ₹1.49 crore/acre in BESCO and applied same value as base rate in Ram Kishan's case.

Exhibits PW4/E and PW4/F (2006 sale deeds) showed ₹95 lakh/acre.

Exhibit PW4/H showed ₹1.80 crore/acre (2007).

PW4/I showed ₹1.30 crore/acre (2010).

High Court chose only PW4/D (₹40.55 lakh/acre), ignoring better comparables nearby.

Supreme Court criticized this selective approach.

Referenced landmark judgments:

Peerappa Hanmantha Harijan (2015) – applied de-escalation.

Chandrashekar (2012) – de-escalation of 10% over 1 year 7 months.

Sardara Singh (2020) – applied escalation based on nearby village awards.

Cited Manoj Kumar v. State of Haryana (2018) – courts must not blindly follow earlier awards, but treat them as evidence, not binding precedents.

But in present case, factual similarity justifies use of BESCO judgment as a base.

Land had clear urban potential: near residential colonies, schools, industries.

Cited precedents that land's “reasonably expected future use” is crucial to valuation.

PW6/1 map showed:

Proximity of Dharuhera to Malpura/Kapriwas.

Sector 5A surrounded by developed sectors.

Reference Court had rightly relied on BESCO’s market value.

₹1.49 crore → De-escalated:

  12% for 1 year = ₹1.31 crore

  6% for 5 months = ₹1.23 crore

  Compared to escalation on PW4/E = ₹1.27 crore → both consistent

Since BESCO landowners paid CLU fees, ₹5 lakh/acre was deducted from ₹1.23 crore.

Final compensation fixed: ₹1.18 crore per acre

SC set aside High Court judgment (RFA No. 701/2022).

Directed payment of ₹1,18,37,668/acre + statutory benefits under:

Section 23(1-A) – additional 12% per annum

Section 23(2) – 30% solatium

Section 28 – interest for delay  

No interest granted for delay in filing appeals.

This judgment is a powerful reminder that:

Landowners are entitled to full, fair, and just compensation.  

Courts must consider the best available sale evidence, not cherry-pick low-value deeds.  

Proximity and potentiality of land are critical to valuation.  

De-escalation or escalation must be applied scientifically based on time differences.  

Citation: 2025 INSC 441 | 2025 LiveLaw (SC) 388  

Court: Supreme Court of India  

Coram: Hon’ble Justices B.R. Gavai and K.V. Viswanathan  

Date of Judgment: April 3, 2025  

Appeal Type: Civil Appeals from High Court of Punjab & Haryana

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