Lal Chand vs Union Of India & Anr

The Supreme Court addressed the determination of market value for lands acquired under the Land Acquisition Act, 1894, specifically under Section 4(1). The Court established that lease premiums for developed plots cannot be used to ascertain the freehold market value of undeveloped land, emphasizing that sale deeds of the acquired or adjacent lands are the most relevant evidence. The Court set aside the Delhi High Court's judgment and remanded the matter for a fresh determination of market value, thereby altering the basis for compensation calculations.