G.M., OIL & NATURAL GAS CORPORATION LTD. vs RAMESHBHAI JIVANBHAI PATEL

The Supreme Court upheld the Reference Court's determination of market value for acquired lands at Rs.17.10 per sq.m, based on prior awards under Section 23(1A) and Section 23(2) of the Land Acquisition Act. The Court found that the Reference Court correctly applied a cumulative increase of 10% per annum over six and a half years, and appropriately adjusted for distance. The High Court's dismissal of the appellant's challenge was affirmed, establishing that proximity and similarity of lands justified the valuation method used.