Land Acquisition Act of 1894 – Section 23(1) – In determining compensation for acquired land, the Court must consider the ‘market value’ of the land- smaller parcels of land conventionally command higher prices. Relying on sale exemplars also, especially when only single solitary such instances are presented, may thus not be appropriate. However, there is no bar in law against considering sale exemplars of smaller plots, provided they are subjected to adequate developmental charges. The rationale behind applying such cuts lies in the fact that smaller plots often command higher prices due to their developed nature, whereas a larger tract of land which is acquired for development may require significant allocation for creating roads, parks, essential services, etc. Accordingly, these sale exemplars can be relied upon only after applying appropriate cuts- When valuing a large block of land, appropriate deduction must be made for setting aside areas for roads, open spaces and dividing the land into smaller plots suitable for the construction of buildings – where there are multiple sale deeds available for consideration, the Court shall rely on the highest valued exemplars unless the prices fall within a narrow range, in which case calculating an average of the values therein may be more congruous- The degree of application of cuts is essentially a question of fact dependent on the unique circumstances of each case, the particulars to be reckoned with in determining the extent of such deduction often include a myriad of factors, such as the relative difference in the size of the land in the sale exemplar vis a vis the acquired land, proximity to a road, nearness to developed areas, etc- Additionally, several decisions have also taken into account the nature of the lands because of the stark difference that may exist between the valuation of an agricultural or undeveloped land and the sale price of a small developed plot in a private layout. (Para 18-31)