CHATURBHUJ. PANDA & ORS. vs THE COLLECTOR, RAIGARH

The Supreme Court held that under Section 23(2) of the Land Acquisition Act, 1894, the High Court erred in disallowing the 15% statutory allowance for the value of trees included in the land acquisition compensation. The Court clarified that 'land' encompasses benefits arising from it, including trees, and thus the value of trees should be considered in determining market value. Additionally, the High Court improperly relied on documents not part of the record without allowing the appellants to rebut, violating principles of natural justice.