Chhattisgarh High Court

Absence of ownership or title in subject land negates locus standi to challenge government land allotment.

RAM BHAGAT AGRAWAL vs STATE OF CHHATTISGARH

Chhattisgarh High CourtJUDGMENT: March 16, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioners claimed ownership and possession of various parcels of land under Khasra numbers in Namnakala, Ambikapur

Source reference: para. 5

They alleged that adjacent Government Nazul land (Khasra No. 243/1) served as their sole access route to their property

Source reference: para. 5

They challenged the legality of the allotment of 0.90 acres of this Nazul land to Respondent No. 4, which occurred on July 10, 2025

Source reference: para. 5-6

Previously, the Nazul Officer had rejected the petitioners' application under Section 131 of the CG Land Revenue Code, 1959, noting they had alternative access

Source reference: para. 6

The State contended that revenue records from 2023-2024 showed the petitioners had transferred their land to third parties and were no longer Bhumiswamis at the time of the allotment, thereby lacking locus standi

Source reference: para. 6

The petitioners contended in their rejoinder that despite selling portions of the land, they retained title over approximately 60 decimals

Source reference: para. 7
02

Issues

1. Whether the petitioners possessed the locus standi to challenge the allotment of Government Nazul land to a third party

Source reference: para. 9

2. Whether the petitioners were entitled to interim relief regarding the access route across the disputed land

Source reference: para. 5, 9
03

Law Applied

Section 131 of the Chhattisgarh Land Revenue Code, 1959, which governs the rights of way and other private easements over the boundaries of other lands

Source reference: para. 6

The Court applied the principle of locus standi, requiring a petitioner to demonstrate a sufficient legal interest or ownership right in the subject matter to maintain a writ petition

Source reference: para. 6, 9
04

Reasoning

The Court examined the revenue documents for the period 2023-2024 submitted by the State, which indicated that the subject land was recorded in the names of persons other than the petitioners

Source reference: para. 9

The Court observed that at the time the government land (Khasra No. 243/1) was allotted to Respondent No. 4 in July 2025, the petitioners did not hold Bhumiswami rights or ownership over the adjacent land

Source reference: para. 9

Despite the petitioners' claim in their rejoinder that they retained 60 decimals of land, the Court found that the current revenue records contradicted their assertion of ownership at the time of the cause of action

Source reference: para. 9

Consequently, the Court determined that because the petitioners did not hold ownership rights when the allotment occurred, they failed to establish the requisite locus standi to maintain the challenge against the State's administrative action

Source reference: para. 9
05

Holding

The High Court dismissed the writ petition at the threshold on the grounds of lack of locus standi

However, the Court granted the petitioners liberty to file a fresh petition should they be able to prove they still hold valid title to any specific portion of the subject land

Source reference: para. 9-10

All pending interlocutory applications, including the prayer for interim relief, were disposed of accordingly

Source reference: para. 11
Chhattisgarh High Court

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RAM BHAGAT AGRAWALvsSTATE OF CHHATTISGARH

Chhattisgarh High Court · March 16, 2026

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