Summary and Analysis of Manohar & Others vs. The State of Maharashtra & Others

1. Heading of the Judgment

Case Title: Manohar & Others vs. The State of Maharashtra & Others
Court: Supreme Court of India
Civil Appeal No.: Arising out of SLP(C) No. of 2025
Judgment Date: July 28, 2025
Judges: CJI B.R. Gavai & Justice Augustine George Masih

2. Related Laws and Sections

• Maharashtra Industrial Development Act, 1961 (Act of 1961): Governed the land acquisition for industrial purposes.

• Land Acquisition Act, 1894 (LA Act):
  Section 18: Reference to the court for enhancement of compensation.
  Section 23: Determines compensation components (market value, solatium, interest).
  Section 51A: Presumptive value of certified copies of sale deeds as evidence.

3. Basic Judgment Details

• Parties:
  Appellants: Farmers (Manohar & Others) whose lands were acquired.
  Respondents: State of Maharashtra & Maharashtra Industrial Development Corporation (MIDC).

• Key Issue: Whether the compensation awarded for acquired land was just, and whether the highest sale exemplar (Rs. 72,900/acre) should be considered.

• Lower Court Decisions:
  Land Acquisition Officer (1994): Awarded Rs. 10,800/acre.
  Reference Court (2007): Enhanced compensation to Rs. 32,000/acre (ignoring the highest exemplar).
  High Court (2022): Upheld the Reference Court’s decision.

4. Explanation of the Judgment

Background

• The appellants’ agricultural land (Survey Nos. 103 & 104) in Village Pungala, Maharashtra, was acquired in the 1990s for an industrial area under the Maharashtra Industrial Development Act, 1961.

• The Land Acquisition Officer initially awarded Rs. 10,800/acre. Dissatisfied, the appellants sought enhancement under Section 18 of the LA Act, citing higher market value based on sale exemplars (Rs. 72,900/acre for a 1990 transaction).

Supreme Court’s Analysis

1. Error in Lower Courts’ Approach:
   The Reference Court and High Court ignored the highest sale exemplar (Rs. 72,900/acre) without justification, despite its proximity to the acquisition date and bona fide nature.
   The High Court contradicted itself by first acknowledging the omission of the highest exemplar (para 49) and later incorrectly stating it was considered (para 50).

2. Legal Principles Applied:
   Highest Exemplar Rule:
   The Supreme Court cited precedents (Anjani Molu Dessai, Mehrawal Khewaji Trust) holding that the highest bona fide sale exemplar must be used unless strong reasons exist to reject it.
   Averaging sale prices is permissible only if values are within a narrow range (e.g., Rs. 40,000–Rs. 41,000/acre), not for widely varying rates (Rs. 25,000–Rs. 72,900/acre).
   Abnormally High Value Argument Rejected:
   The respondents argued the Rs. 72,900/acre exemplar was "abnormally high," but the Court noted:
   The land was prime location (near Nashik-Nirmal Highway, Jintur town, with water access).
   Post-acquisition sale instances (1992–1993) showed prices rising to Rs. 60,000/acre, validating the 1990 exemplar.
   Deduction for Large Land Area:
   The Court upheld a 20% deduction (from Rs. 72,900 to Rs. 58,320/acre) to account for the larger acquired plot size vs. small exemplar plots.

3. Final Decision:
   The Supreme Court set aside the High Court and Reference Court orders.
   Enhanced compensation to Rs. 58,320/acre (after 20% deduction from Rs. 72,900/acre).
   Consequential benefits (solatium, interest under Sections 23(1-A), 23(2), and 28 of the LA Act) were granted.

5. Key Takeaways

• Legal Precedent: Reinforces that the highest bona fide sale exemplar must be the basis for compensation unless disproven.

• Fair Compensation: Landowners are entitled to potential value (non-agricultural use, location advantages) of acquired land.

• Judicial Clarity: Lower courts must record reasons for rejecting evidence (e.g., sale exemplars) to avoid arbitrary decisions.