A reasoned order cannot be reviewed without recorded grounds, absent exceptional fraud or material factual distortion.

The dispute concerned land situated at Mauza Jalalpur, Thana No. 22, Khata No. 14, Khesara No. 149, measuring approximately 4,658 sq. ft.

Respondent Nos. 8 and 9 had challenged an order of the Deputy Collector Land Reforms, Danapur, in Land Dispute Case No. 9 of 2023–24 before the Divisional Commissioner, Patna, in Land Dispute Appeal Case No. 110 of 2024.

After hearing the petitioner, respondent Nos. 8 and 9, and the State, the Divisional Commissioner passed a reasoned order dated 11 March 2025 rejecting the appeal and granting liberty to the parties to approach the competent court.

Thereafter, respondent Nos. 8 and 9 filed a review petition, alleging that the petitioner had obtained the DCLR’s order by practising fraud or misrepresentation; however, the review petition did not identify any specific error, fraud, misrepresentation, or patent illegality warranting review.

On 22 May 2025, the Divisional Commissioner withdrew/reopened the earlier order and called for a joint investigation report from the DCLR, Danapur, and the S.D.P.O., Danapur, without recording reasons for reopening the matter.

The petitioner challenged this order under Article 226 of the Constitution.

Whether the Divisional Commissioner could review or reopen his reasoned order dated 11 March 2025 without recording the grounds or circumstances warranting such review?

Whether the order dated 22 May 2025 was legally sustainable when neither the review petition nor the reopening order disclosed any specific fraud, misrepresentation, error, or patent illegality affecting the earlier decision?

The Court applied the general principles governing review by a quasi-judicial authority: a reasoned and final order cannot ordinarily be reviewed merely because the authority wishes to reconsider the matter; review must be supported by legally recognisable grounds such as fraud, material misrepresentation, or an error/patent illegality affecting the decision.

Even in exceptional cases where review may be permissible, the reviewing authority must record its satisfaction and reasons for reopening the matter. A reasoned order cannot be reviewed without reasons.

The Divisional Commissioner had already heard all concerned parties and passed a reasoned order on 11 March 2025 rejecting the appeal.

The subsequent review petition did not point out any particular error, fraud, misrepresentation, or patent illegality that had affected the earlier decision.

Although fraud or material distortion of facts could, in an exceptional case, justify review, respondent Nos. 8 and 9 failed to identify what fraud had been committed or what misrepresentation had influenced the original order.

Further, the Divisional Commissioner’s order dated 22 May 2025 merely reopened the proceedings and called for an investigation report, but did not record why the earlier reasoned order required reconsideration.

The absence of reasons rendered the exercise of review jurisdiction legally unsustainable.

The order dated 22 May 2025 in Land Dispute Appeal Case No. 110 of 2024 was quashed.

The parties were left free to pursue appropriate legal remedies against the original order dated 11 March 2025, and the High Court clarified that it had not examined the merits of the underlying land dispute.

The writ petition was accordingly allowed and disposed of without costs.