Introduction:

The case Mala Etc. Etc. vs. State of Punjab & Others (decided on August 17, 2023) revolves around the issue of fair compensation for land acquisition by the State of Punjab under the Land Acquisition Act, 1894. The appellants, whose agricultural land was taken for a public purpose, contested the compensation fixed by the Land Acquisition Collector, arguing it was below the market value. The Supreme Court examined whether further enhancement was justified beyond the High Court’s decision, which had already increased the compensation and granted statutory benefits.

Background:

The State of Punjab acquired agricultural land belonging to the appellants. The Land Acquisition Collector initially awarded low compensation. Dissatisfied, the landowners approached the Reference Court, which made a slight enhancement. The High Court then increased the compensation to ₹2,000 per marla and included statutory benefits under Sections 23(1A), 23(2), and 28 of the Act. The appellants, still unsatisfied, appealed to the Supreme Court, seeking a higher valuation.

Key Developments:

• The appellants claimed the High Court failed to consider comparable sale deeds indicating higher market rates.

• The respondents (State) argued that ₹2,000 per marla was fair and based on proper evidence, as the land was primarily agricultural with limited urban potential.

• The Supreme Court analyzed both sides’ arguments, focusing on whether the High Court had erred in determining the fair market value.

Issues:

1. Was the compensation of ₹2,000 per marla just and fair in light of the prevailing market rate?

2. Were the appellants entitled to further enhancement of compensation?

3. Were statutory benefits under Sections 23(1A), 23(2), and 28 properly granted?

4. Did the High Court correctly assess the land’s potential and sale comparisons?

Current Status (Judgment):

The Supreme Court upheld the High Court’s decision and rejected the appeal. The Court held that:

• The compensation fixed at ₹2,000 per marla was reasonable and evidence-based.

• The land was primarily agricultural with limited developmental prospects at the time of acquisition.

• Statutory benefits under the Land Acquisition Act were correctly applied.

• No further enhancement was warranted as the High Court’s valuation aligned with legal precedents and market evidence.

Conclusion:

The Supreme Court reaffirmed the High Court’s findings, ruling that the compensation of ₹2,000 per marla was fair, equitable, and in accordance with law. The Court highlighted the importance of balancing the rights of landowners with public interest while ensuring just compensation under the Land Acquisition Act. The appeal was dismissed, confirming the High Court’s judgment in full.