SPECIAL LAND ACQUISITION OFFICER CITY IMPROVEMENTTRUST BOAR vs P. GOVINDAN

The Supreme Court held that for determining market value under Section 23(1) of the Land Acquisition Act, the relevant date is the notification under Section 4(1) rather than Section 6. The Court clarified that the 1927 amendment to Section 23(1) constituted a valid substitution, effectively repealing the previous provision. Consequently, the appeal was allowed, and the case was remanded to the High Court for market value determination based on the Section 16 notification date under the City of Mysore Improvement Act, 1903.