​As of April 22, 2025, there is no publicly available Supreme Court ruling specifically stating that the market value of acquired land under the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement (RFCTLARR) Act must be determined based on the date of the Section 11 notification. However, existing legal provisions and prior judgments provide clarity on this matter.​

Legal Framework and Judicial Interpretations

Under Section 26 of the RFCTLARR Act, 2013, the market value of land is to be determined based on the date of the preliminary notification issued under Section 11 of the Act. This provision aligns with the earlier Land Acquisition Act, 1894, where the market value was assessed as of the date of the preliminary notification under Section 4(1) .

In cases where land acquisition proceedings were initiated under the 1894 Act but no award was made before the commencement of the RFCTLARR Act on January 1, 2014, Section 24(1)(a) of the 2013 Act applies. This section stipulates that all provisions of the 2013 Act relating to compensation determination shall apply, and the market value should be assessed as of January 1, 2014 .​

Furthermore, the Supreme Court has held that determining market value based on land acquisitions occurring years after the original notification is impermissible, as it would not reflect the accurate value at the time of the initial acquisition process .​

Conclusion

While there may not be a new Supreme Court ruling on this specific issue as of today, the legal position remains that the market value of acquired land under the RFCTLARR Act should be determined based on the date of the preliminary notification issued under Section 11. In transitional cases from the 1894 Act to the 2013 Act, if no award was made before January 1, 2014, the market value is to be assessed as of that date.

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