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Why infer an area law from astronomy? In the authored account The great Martian catastrophe and how Kepler fixed it by Owen Gingerich, a 13 August 1593 Mars observation has ecliptic longitude $346^{\circ }7.5^{\prime }$, against predicted $342^{\circ }{0}^{\prime }$ and $351^{\circ }26^{\prime }$. These are Earth-based directions with a date, not measured Sun-based areas. The observer's armillary sphere used graduated circles and sighting arms to read declination; reversing it allowed a second reading. Comparing stars at different altitudes exposed refraction, and a planet-based check revealed an erroneous solar correction table. The apparent Mars distance signal had been contaminated by that correction. Johannes Kepler subsequently corrected the observer's Earth orbit, then tested Mars trajectories. The account describes typical angular errors of $2^{\prime }$ or less ($120$ arcseconds): small residuals needed care.^[ref]

The Tufts class notes Kepler's Astronomia Nova and the Orbit of Mars explain the key limitation: an area requires a trajectory and distances, so Kepler's second law cannot be directly tested from angular observations alone. They describe checking the combined ellipse and area law against 28 dated observations around seven oppositions during 1583-1595, using an Earth model to predict Earth-based directions; agreement improved greatly but some discrepancies remained.^[ref]

The inferential chain is useful today too: recover relative positions and times, compare swept areas, and ask what forces are compatible with their evolution. Agreement with equal areas supports zero torque about the chosen origin under the assumptions below; it alone does not identify an inverse-square law. Recovering the radial force also needs the trajectory and its timing, as in inferring an inverse-square force from Kepler laws. The two diagrams here are calculated examples, not the historical measurements.