Project Director, National Highways Authority of India v. Alfa Remidis Ltd. 2026 INSC 480 - Average Sale Price- RFCTLARR Act
Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 - Section 26 ; National Highways Act, 1956 - The methodology for working out the ‘average sale price’ under Section 26(1)(b), as set out in Explanations 1 to 4 thereunder, does not permit placing reliance on a single sale deed for that purpose. There should be multiple deeds available for reference, as singular deals may not supply adequate and reliable data. (Para 11) [Context: The Supreme Court held that while determining compensation under the National Highways Act, the methodology in section 26 must be followed, and the Arbitrator had erred by relying on a single sale deed of a small residential plot in a different village to value industrial land. Treating this as a patent illegality on the face of the award, the Court set aside the enhanced rate.]
Case Info
Case information extracted
Case name: Project Director, National Highways Authority of India v. Alfa Remidis Ltd. and others
Neutral citation: 2026 INSC 480
Coram:Justice Sanjay KumarJustice K. Vinod Chandran
Judgment date: 12 May 2026
Statutes / laws referred:Indian Stamp Act, 1899National Highways Act, 1956 (NH Act), especially sections 3A, 3G(1), 3G(5)Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 (2013 LA Act), especially section 26 and First Schedule; Fourth Schedule; Removal of Difficulties Order, 2015Arbitration and Conciliation Act, 1996 (Arbitration Act), sections 34 and 37
Caselaws and citations mentioned:National Highways Authority of India v. P. Nagaraju @ Cheluvaiah and another, (2022) 15 SCC 1Madhya Pradesh Road Development Corporation v. Vincent Daniel and others, (2025) 7 SCC 798
Three‑sentence brief summary
The Supreme Court held that while determining compensation under the National Highways Act, the methodology in section 26 of the 2013 LA Act must be followed, and the Arbitrator had erred by relying on a single sale deed of a small residential plot in a different village to value industrial land. Treating this as a patent illegality on the face of the award, the Court set aside the enhanced rate of ₹3,588 per sq. m. and instead adopted the Ready Reckoner “government rate” of ₹2,020 per sq. m. applicable to highway lands in the relevant zone under section 26(1)(a). The appeal by NHAI was accordingly allowed, with compensation recalculated at ₹2,020 per sq. m. along with all consequential statutory benefits, adjusting the ₹50,00,000 already withdrawn.