The Supreme Court, while deciding a case on market value determination for compulsorily acquired land, flagged that India's land acquisition framework is fragmented: the general Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 uses a modern, multiplier-based valuation formula, but several 'special' enactments (for highways, railways, coal-bearing areas, electricity infrastructure) still use older, less generous methods inherited from the Land Acquisition Act, 1894. The Court urged the Centre to bring parity across statutes.
Constitutionally, deprivation of property is governed by Article 300A, which only requires that acquisition be backed by valid law, not that compensation be fixed uniformly. Since property is no longer a fundamental right (post the 44th Amendment removal of Articles 19(1)(f)/31), courts cannot test acquisition laws on that heightened standard. The disparity instead raises an Article 14 concern: similarly placed landowners losing comparable land for comparable public purposes get unequal compensation solely due to which statute was invoked, without rational nexus to any legitimate objective.
Exam takeaway: know the shift from Article 31 to Article 300A, the significance of the 2013 Act replacing the 1894 Act, and that Parliament aligned only some scheduled special Acts' compensation with the 2013 formula—leaving the anomaly the Court flagged.