Once Proximity and Potential Are Proved, Compensation Must Be Fair:  Supreme Court Enhances Land Rates in Jintur MIDC Land Acquisition Case

“Selection of the acquired lands for establishment of M.I.D.C. indicates their prime location” —  Supreme Court of India, in Ashok S/o Vitthalrao Jagtap v. State of Maharashtra & Others, allowed a batch of civil appeals (arising out of SLP(C) Diary Nos. 25098, 25113, 25784, 28984, 28985, 28986, 32770, 32771 of 2025), granting enhanced compensation to landowners whose lands were acquired in the 1990s for setting up a Maharashtra Industrial Development Corporation (MIDC) project near Jintur, Parbhani District. The judgment was delivered by a Bench comprising Chief Justice B.R. Gavai and Justice K. Vinod Chandran.

Declaring that the appellants were “similarly situated” to the landowners in Manohar & Others v. State of Maharashtra, the Court enhanced compensation from ₹32,000 per Acre to ₹58,320 per Acre, along with statutory benefits under the Land Acquisition Act, 1894.

“We find that the contention... that the acquired lands are at a distance of 5 km from Jintur town cannot be accepted” — Court dismisses MIDC’s claim of remoteness

The core issue revolved around whether the appellants were entitled to compensation on par with that awarded in Manohar’s case. The State had initially awarded ₹32,000 per Acre for the acquisition. Though the Reference Court increased the amount, the High Court reversed this, dismissing the landowners’ claims for enhancement.

In assessing the legitimacy of the appeal, the Apex Court drew heavily from the High Court’s own admission in para 46 of its impugned judgment, which had recognized the advantageous positioning of the acquired lands:

“It is evident from the testimony of the claimants that the acquired lands are more convenient for the establishment of MIDC Jintur... The claimants have also placed on record the documentary evidence... Certainly, the argument... that the acquired lands are at a distance of 5 km... cannot be accepted.”

This finding became pivotal, as the Court emphasized that the lands were adjacent to Jintur town, near the Nashik-Nirmal State Highway, and had N.A. (non-agriculture) potential, with irrigation facilities available nearby. The Court concluded that the land's characteristics warranted the same compensation as that granted in Manohar.

“Deduction of 20% from exemplar sale price is reasonable” — Comparable Sale Method upheld, small-plot sale price adjusted for large acquisition

In Manohar, decided earlier on 28 July 2025, the Supreme Court had assessed similar acquisitions in the same region. The Reference Court had accepted ten sale exemplars, the highest of which showed land value at ₹72,900 per Acre. Recognizing that these were smaller urban plots, the Court applied a 20% deduction to arrive at ₹58,320 per Acre for acquisition purposes.

Applying the same principle here, the Court affirmed:

“The Appellants being similarly situated to the ones before this Court in the case of Manohar... the present appeals also deserve to be allowed in the same terms.”

“Financial delay cannot deprive landowners of justice” — Interest awarded, except for delay period

Although the Court granted all statutory benefits under Sections 23(1-A), 23(2), and 28 of the Land Acquisition Act, it declined interest on the enhanced amount for the period of delay in filing the Special Leave Petitions, in accordance with its earlier directions issued during notice stage.

Nonetheless, the core relief remained intact. The Reference Court’s judgment enhancing compensation was restored, and the High Court’s reversal of the same was explicitly set aside.

Supreme Court Issues Clear Directions for Compensation

Summing up its verdict, the Bench passed the following operative directions:

“We direct that the compensation granted to the Appellants be enhanced from ₹32,000/- per Acre to ₹58,320/- per Acre. We further direct that all other consequential benefits of solatium and interest on the enhanced compensation in terms of Section 23(1-A), 23(2), and 28 of the Land Acquisition Act, 1894, be granted to the Appellants.”

The Court, however, reiterated that no interest shall be paid for the period of delay in approaching the Court, as already notified in earlier proceedings.

This ruling reinforces the Supreme Court’s consistent approach to ensuring parity among landowners whose lands were similarly situated, similarly acquired, and similarly adjudicated. By invoking its prior decision in Manohar, the Court ensured uniformity, predictability, and fairness in state acquisition matters — a critical aspect in maintaining public trust in land compensation jurisprudence.

Date of Decision: November 18, 2025