Allahabad HC Holds Article 227 Covers Section 66 Revenue Proceedings, Directs Authority To Conclude Pending Inquiry Preferably Within 3 Months

The petitioner sought a direction for expeditious conclusion of proceedings under Section 66 of the Uttar Pradesh Revenue Code, 2006, registered as Case No. 2025468001098.

The proceedings had been pending since 2025 before the Chief Revenue Officer, following a Tehsildar’s reference dated 7 April 2025 made in compliance with an order in PIL No. 1134 of 2024.

The petitioner argued that Article 227 empowered the High Court to direct the revenue authority to conclude the case, relying on Kuldeep Yadav v. State of U.P. & Ors., Special Appeal No. 351 of 2025.

The State opposed the petition, submitting that the authority hearing the Section 66 proceeding was not a “court” for Article 227 purposes and that the petitioner should instead proceed under Article 226.

Article 227(1) of the Constitution gives the High Court superintendence over courts and tribunals within its jurisdiction.

Section 2(a) of the Bharatiya Sakshya Adhiniyam, 2023 defines “Court” to include Judges, Magistrates and persons legally authorised to take evidence.

Section 4(16) of the Uttar Pradesh Revenue Code, 2006 includes Collectors, Additional Collectors and Chief Revenue Officers within the definition of “Revenue Court”.

Rule 65 of the Uttar Pradesh Revenue Code Rules, 2016 prescribes the inquiry procedure under Section 66, including notice and an opportunity for interested persons to present their case, and directs the Collector to endeavour to conclude the inquiry within six months.

The Court also referred to Ramvraksha alias Kalicharan v. State of U.P., Writ-C No. 21931 of 2020, concerning the quasi-judicial character of proceedings under Section 67 of the Code, and to Daya Shanker v. State of U.P. & Ors., 2023 (6) ADJ 181, in connection with the disposal direction.

The Court considered the procedure under Rule 65, including the requirement to hear the allottee and Land Management Committee and the provision for interested parties to present their cases.

It treated the Section 66 inquiry as quasi-judicial rather than merely executive and concluded that the revenue authority conducting it was legally authorised to take evidence for purposes of the definition in Section 2(a) of the Bharatiya Sakshya Adhiniyam.

Because Section 4(16) expressly includes the Collector and Chief Revenue Officer among Revenue Courts, the Court held that the authority hearing the proceeding fell within Article 227’s supervisory reach.

It therefore rejected the State’s objection to maintainability and the reporting-section defect.

It directed the opposite party no. 1 to conclude Case No. 2025468001098 expeditiously, preferably within three months, in light of Daya Shanker; the petition was disposed of accordingly.