Madhya Pradesh High Court
Administrative and Public LawConstitutional Law

A challenge to the Collector’s inquiry is premature before a final order is passed.

Dhanko Parihar vs The State Of Madhya Pradesh Through The Principal Secretary

Madhya Pradesh High CourtJUDGMENT: October 05, 20262 MIN READSOURCE JUDGMENT
A challenge to the Collector’s inquiry is premature before a final order is passed.. Dhanko Parihar vs The State Of Madhya Pradesh Through The Principal Secretary. Madhya Pradesh High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioners approached the High Court under Article 226, challenging proceedings initiated by the Collector after an earlier order dated 18 June 2026 directed the competent authority to consider and decide their representation concerning alleged false complaints and their rights in specified survey numbers.

Source reference: para. 1

They contended that the Collector had expanded the inquiry into the grant of pattas and issued notices to persons beyond the scope of that representation and the earlier writ petition.

Source reference: paras. 2–4

The State submitted that notices followed anomalies identified while considering the representation.

Source reference: paras. 8–9

No final order had been passed by the Collector when the present petition was heard.

Source reference: para. 10
02

Issues

Whether the Collector’s inquiry and notices exceeded the scope of the High Court’s earlier direction to consider and decide the petitioners’ representation

Source reference: paras. 2–4, 8–9

Whether the petition challenging the ongoing proceedings was premature in the absence of a final order by the Collector

Source reference: para. 10
03

Law Applied

The Court considered the scope of its earlier direction to the competent authority to consider and decide the petitioners’ representation, and the Collector’s authority to examine relevant aspects and pass a reasoned order on the material available.

Source reference: paras. 8–9

It also applied the principle that a challenge to proceedings still under consideration may be premature where no final order has been passed.

Source reference: para. 10

Article 226 was the basis of the petition.

Source reference: para. 1

The Court noted the petitioners’ reliance on Abhishek Gupta v. Dinesh Kumar & Ors., but held that the precedent was not applicable to the case at that stage.

Source reference: paras. 5, 11
04

Reasoning

The Court found that the Collector had called for reports while considering the representation and, on the material received, considered it appropriate to issue notices to other persons.

Source reference: paras. 8–11

In the circumstances, this step was not shown to be without jurisdiction or outside the earlier direction; the Collector remained entitled to examine relevant aspects and issue a reasoned order.

Source reference: paras. 8–11

Because that process was ongoing and no final order had been made, the Court declined to intervene at that stage.

Source reference: paras. 10–11
05

Holding

The Court held that the petition was premature and devoid of merit, dismissed it, and declined admission.

No relief was granted against the pending proceedings.

Source reference: paras. 10–12
Madhya Pradesh High Court

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Dhanko PariharvsThe State Of Madhya Pradesh Through The Principal Secretary

Madhya Pradesh High Court · October 05, 2026

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