Dismissed¶20

Jagmender v. Dist Revenue Officer & Ors.

Punjab & Haryana HC10 Apr 2026RFA/502/2014

Case brief

AI extract

What is this about?

Punjab & Haryana High Court, RFA-502-2014 and ten connected RFAs (Deepak Gupta, J.; reserved 08.04.2026, pronounced 10.04.2026): land acquisition compensation, Sonepat (villages Mehlana and Barwasni; Carrier Lined Channels; notification dated 03.03.2006). Enhancement from Rs. 12,50,000 to Rs. 16,00,000 per acre upheld solely on prior award Mark-A dated 10.04.2008 (proximity in time, similar purpose, comparable location, attained finality); rival sale instances (Mark-B to Mark-D; Mark D1-D3) rejected for non-comparability; all landowner and State appeals dismissed, Reference Court awards affirmed.

What did the court decide?

None; all eleven appeals (six by landowners, five by the State) dismissed and the Reference Court awards affirmed, with the landowners entitled to statutory benefits as already granted; no order as to costs. ¶20

Jagmender Vs Dist Revenue Officer & Ors. — Land Acquisition | Punjab & Haryana HC (2026)

What the court decided

AI extract

Outcome

¶20

Issue for consideration

Whether the Reference Court correctly determined the fair market value of the acquired land at Rs. 16,00,000/- per acre, and whether any further enhancement or reduction is warranted. +1 more

¶9

Court's answer

The reliance placed by the Reference Court on the previous award dated 10.04.2008 (Mark-A) is legally sound, as it satisfies the tests of proximity in time, similarity of purpose, and comparability of location.

¶16

Ratio / Principle

The landowners' sale instances (Mark-B to Mark-D) pertain to small parcels whose comparability with the acquired land was never established; lacking site plan or cogent foundational evidence, the Reference Court rightly discarded them.

¶14

Key takeaways

The State's sale instances (Mark D1 to D3) were likewise unsupported by credible evidence of location or comparability, and the State's failure to produce a site plan justified their exclusion from consideration.ratio¶15
Since it was never shown that the Mark-A award was challenged or modified by any superior court, it can safely be treated as having attained finality and thus constitutes a reliable benchmark for determining market value.ratio¶17
Finding no infirmity in the Reference Court's approach, this Court holds that it adopted a just, fair, and legally sustainable approach in determining the market value at Rs. 16,00,000/- per acre.

Detailed headnote1 paragraphs

Eleven connected Regular First Appeals under Section 54, Land Acquisition Act 1894, arising out of a common acquisition notified on 03.03.2006 (Section 4) and declared on 10.05.2006 (Section 6) for construction of Carrier Lined Channels in villages Mehlana and Barwasni, District Sonepat. The Land Acquisition Collector had assessed Rs. 12,50,000/- per acre (Award Nos. 7 and 10 of 2006); the Reference Court, Sonepat enhanced the value to Rs. 16,00,000/- per acre relying on the previous award dated 10.04.2008 (Mark-A) concerning Mehlana land acquired under the same notification. Sale instances urged by the landowners (Mark-B to Mark-D) and by the State (Mark D1 to D3) were discarded as lacking site plans and proof of location or comparability. Holding that reliance on Mark-A satisfied the tests of proximity in time, similarity of purpose and comparability of location, and that the award, never challenged, stood finalised as a reliable benchmark, the Court found no ground for further enhancement or reduction, dismissed all appeals and affirmed the awards with statutory benefits already granted; no order as to costs.

¶1

RFA-502-2014 [1]

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IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH

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RFA-502-2014 and other connected ma#ers

¶4

Jagmender (through LRs) ...Appellant

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Versus

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District Revenue Officer-cumLand Acquisi(on Collector and Others ...Respondents

¶7

Reserved on: 08.04.2026 Pronounced on: 10.04.2026 Pronounced fully/opera0ve part: Fully

¶8

CORAM: HON'BLE MR. JUSTICE DEEPAK GUPTA

¶9

Argued by: Ms. Anita Balyan, Advocate with Mr. Vicky Chauhan, Advocate for the appellant (in RFAs-502-504-2014, RFA-224-2015) & for the respondent (in RFA-393 to 396-2014).

¶10

Mr. Gaurav Garg, AAG, Haryana.

¶11

Mr. Vikas Lochas, Advocate and Mr. Madhav S. Megha, Advocate for the appellants (in RFA-287-2015) and for respondent (in RFA-721-2015)

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¶13

DEEPAK GUPTA, J.

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This judgment shall govern the adjudica(on of eleven Regular First Appeals, as tabulated below, preferred under Sec(on 54 of the Land Acquisi(on Act, 1894, arising out of a common acquisi(on process and substan(ally similar awards rendered by the Reference Court, Sonepat. Out of these appeals, six have been ins(tuted by the landowners seeking enhancement of compensa(on, whereas five have been preferred by the State of Haryana assailing the enhancement granted by the Reference Court, which are tabulated here under:-

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YOGESH MEHTA 2026.04.10 16:29 I attest to the accuracy and integrity of this document

¶16

RFA-502-2014 [2]

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Sr No.	RFA No.	Appellants	LA Case No.	Date of decision of Reference Court
1	502/2014	Jagmender vs. District Revenue Officer and others	92/2010/ 2013	30.04.2013
2	503/2014	Moji Ram and others vs. District Revenue Officer and others	93/2010/ 2013	30.04.2013
3	504/2014	Rajinder Singh and another vs. District Revenue Officer and others	95/2010/ 2014	30.04.2013
4	393/2014	State of Haryana and others vs. Jagmender	92/2010/ 2013	30.04.2013
5	394/2014	State of Haryana and others vs. Darshan Singh	94/2010/ 2013	30.04.2013
6	395/2014	State of Haryana and others vs. Moji and others	93/2010/ 2013	30.04.2013
7	396/2014	State of Haryana and others vs. Rajinder Singh and another	95/2010/ 2013	30.04.2013
8	2767/2014	Darshan Singh vs. District Revenue Officer and others	94/2010/ 2013	30.04.2013
9	224/2015	Ashok Kumar and others vs. State of Haryana and others	1478/2013	12.08.2014
10	287/2015	Chander Singh vs. State of Haryana and others	23/2012/ 2013	23.05.2014
11	721/2015	State of Haryana and others vs. Chander Singh	23/2012/ 2013	23.05.2014

¶18

All the appeals, barring two, pertain to the acquisi(on of land situated in village Mehlana, District Sonepat, thereby involving common ques(ons of fact and law rela(ng to determina(on of fair market value. The remaining two appeals, namely RFA Nos. 287 of 2015 and 721 of 2015, relate to land situated in village Barwasni of the same district. However, as is evident from the record, the acquisi(on therein emanates from the same no(fica(on and is for an iden(cal public purpose, thus warran(ng their analogous considera(on.

¶19

YOGESH MEHTA 2026.04.10 16:29 I attest to the accuracy and integrity of this document

¶20

RFA-502-2014 [3]

¶21

In view of the commonality of the acquisi(on no(fica(ons, the purpose of acquisi(on, the nature of evidence led, and the issues arising for determina(on, par(cularly with respect to the assessment of market value, this Court deems it appropriate to decide all these appeals by way of a common judgment, so as to ensure consistency in judicial determina(on and to avoid conflic(ng findings.

¶22

Facts and Background : It emerges from the record that land measuring 4.55 acres situated in village Mehlana, and 0.4 acres situated in village Barwasni, belonging to different landowners, was no(fied on 03.03.2006 for acquisi(on under Sec(on 4 of the Land Acquisi(on Act, 1894. This was followed by a declara(on under Sec(on 6 of the Act vide no(fica(on dated 10.05.2006, for a public purpose, namely, construc(on of Carrier Lined Channels. The Land Acquisi(on Collector, Sonepat, vide Award No.7 dated 31.08.2006, assessed the market value of the land in village Mehlana at ₹12,50,000/- per acre. Similarly, vide Award No.10 dated 21.09.2006, the market value of land in village Barwasni was also assessed at ₹12,50,000/- per acre.

¶23

Dissa(sfied with the aforesaid awards, the landowners sought references under Sec(on 18 of the Act. The Reference Court, Sonepat, decided a batch of such references vide award dated 30.04.2013, assessing the market value at ₹16,00,000/- per acre, along with statutory benefits. Other connected references were decided on 12.08.2014 and 23.05.2014, wherein the same rate of ₹16,00,000/- per acre was awarded.

¶24

These awards have given rise to the present set of appeals—six by the landowners seeking further enhancement, and five by the State of Haryana seeking reduc(on or seIng aside of the enhancement granted by the Reference Court.

¶25

Submissions of the Par�es : Learned counsel for the YOGESH MEHTA landowners contends that the Reference Court has erred in placing sole 2026.04.10 16:29 I attest to the accuracy and integrity of this document reliance upon a prior award dated 10.04.2008 (Mark-A) pertaining to village

¶26

RFA-502-2014 [4]

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Mehlana, wherein land acquired through no(fica(on dated 03.03.2006 for a similar purpose was assessed at ₹16,00,000/- per acre. It is argued that the Reference Court failed to consider relevant sale instances (Mark-B to Mark-D) as well as the Aks Shajra, which, according to the landowners, would have jus(fied a higher determina(on of market value.

¶28

Per contra , learned State counsel submits that the Reference Court was not jus(fied in enhancing the compensa(on from ₹12,50,000/per acre to ₹16,00,000/- per acre solely on the basis of the previous award (Mark-A). It is argued that in the said award, the Land Acquisi(on Collector himself had assessed the market value at ₹16,00,000/- per acre, which was merely affirmed by the Reference Court. Therefore, the same could not form a valid basis for enhancement in the present case. It is further contended that sale instances (Mark D1 to D3) and the site plan (Mark-D4) produced by the State have also not been properly appreciated.

¶29

Points for Determina�on : The principal ques(on that arises for considera(on is whether the Reference Court has correctly determined the fair market value of the acquired land at ₹16,00,000/- per acre, and whether any further enhancement or reduc(on is warranted in the facts and circumstances of the case.

¶30

Legal Posi�on : It is well-seJled that the determina(on of market value under the Land Acquisi(on Act is to be made on the basis of what a willing purchaser would pay to a willing seller in an open market transac(on, having due regard to the exis(ng advantages and poten(al of the land, while excluding any increase in value aJributable to the scheme of acquisi(on itself.

¶31

The burden to establish that the market value assessed by the Land Acquisi(on Collector is inadequate lies upon the claimants. The evidence led must be cogent, reliable, and comparable in nature. Sale YOGESH MEHTA2026.04.10 16:29 instances relied upon must be proximate in (me, comparable in nature, and I attest to the accuracy and integrity of this document duly proved, including their loca(on vis-à-vis the acquired land.

¶32

RFA-502-2014 [5]

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It is equally seJled that previous awards rela(ng to acquisi(on of land in the vicinity, arising out of similar no(fica(ons and for similar purposes, cons(tute relevant and admissible evidence, provided they have aJained finality and are shown to be comparable.

¶34

Apprecia�on of Evidence : Upon a careful considera(on of the record and the rival submissions, this Court finds no infirmity in the approach adopted by the Reference Court.

¶35

The sale instances (Mark-B to Mark-D) relied upon by the landowners pertain to small parcels of land. However, the landowners failed to establish their comparability with the acquired land. No site plan or cogent evidence was produced to demonstrate the loca(on, poten(al, or similarity of these parcels vis-à-vis the acquired land. In the absence of such founda(onal evidence, the Reference Court rightly discarded these sale instances.

¶36

Similarly, the sale instances (Mark D1 to D3) relied upon by the State were also unsupported by any credible evidence regarding their loca(on or comparability. The failure of the State to produce a site plan or other relevant material jus(fied their exclusion from considera(on.

¶37

Consequently, the Reference Court was leM with the previous award dated 10.04.2008 (Mark-A), which pertained to land in village Mehlana acquired under a no(fica(on of the same date i.e. 03.03.2006 and for a similar public purpose. The reliance placed upon this award is legally sound, as it sa(sfies the tests of proximity in (me, similarity of purpose, and comparability of loca(on.

¶38

Significantly, it has not been shown that the said award (MarkA) was ever challenged or modified by any superior court. In the absence of any evidence to the contrary, the said award can safely be treated as having aJained finality and thus cons(tutes a reliable benchmark for determining

¶39

YOGESH MEHTA 2026.04.10 16:29 I attest to the accuracy and market value. integrity of this document

¶40

RFA-502-2014 [6]

¶41

Conclusion : In view of the foregoing discussion, this Court is of the considered opinion that the Reference Court has adopted a just, fair, and legally sustainable approach in determining the market value of the acquired land at ₹16,00,000/- per acre.

¶42

No ground is made out either for further enhancement, as sought by the landowners, or for reduc(on, as prayed for by the State of Haryana.

¶43

Accordingly, all the appeals—filed by both the landowners as well as the State—are hereby dismissed. The awards passed by the Reference Court are affirmed. The landowners shall be en(tled to all statutory benefits, as already granted by the Reference Court. No order as to costs.

¶44

10.04.2026 (DEEPAK GUPTA) Yogesh JUDGE Whether speaking/reasoned:- Yes/No Whether reportable:Yes/No

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Uploaded on : 10.04.2026

¶46

YOGESH MEHTA 2026.04.10 16:29 I attest to the accuracy and integrity of this document

Jagmender v. Dist Revenue Officer & Ors.

Case brief

What is this about?

What did the court decide?

Jagmender v. Dist Revenue Officer & Ors.

Case brief

What is this about?

What did the court decide?

Why is it important?

What the court decided

Issues for consideration

Statutes considered

Procedural history

Parties & counsel

Coram

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