Rajasthan High Court

Creation of revenue villages is an administrative prerogative and cannot be invalidated solely due to political origination.

SATYANARAYAN SINGH RAJPUROHIT vs STATE OF RAJASTHAN

Rajasthan High CourtJUDGMENT: June 11, 20263 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The State Government issued notifications in early 2025 prescribing guidelines for the delimitation of Panchayats and the creation of revenue villages under the Rajasthan Panchayati Raj Act, 1994, and the Rajasthan Land Revenue Act, 1956

Source reference: p. 2

On 22.03.2025, the village "Khichan Vistar" was created

Source reference: p. 3

Following objections by the petitioner regarding the distance between the old and new village centers, an inquiry report dated 26.08.2025 noted that while the distance met the 1km criteria, certain Khasras were adjacent

Source reference: p. 4-5

Based on this, the Collector recommended cancellation, and the State issued a notification on 17.11.2025 withdrawing the village’s creation

Source reference: p. 5

Subsequently, following a representation by a local political leader and a factual review of previous reports, the State issued the impugned notification dated 13.12.2025, restoring/re-creating "Khichan Vistar"

Source reference: p. 6
02

Issues

1. Whether the notification dated 13.12.2025 creating revenue village "Khichan Vistar" violated the prescribed distance and population norms

Source reference: p. 6, para 3

2. Whether an administrative decision to create a revenue village can be quashed solely on the ground that the proposal originated from a political representation

Source reference: p. 6, para 3.2

3. Whether the State is empowered to issue a fresh notification for the creation of a village after a previous notification had been withdrawn

Source reference: p. 12, para 8.1
03

Law Applied

Section 16 of the Rajasthan Land Revenue Act, 1956, which grants the State Government absolute power to create, abolish, or alter the limits of divisions, districts, and villages via official gazette

Source reference: p. 12

Principle from State of Punjab v. Tehal Singh and Poonma Ram v. State of Rajasthan, establishing that the creation of revenue villages is an administrative/policy act, not a legislative one, and thus subject to limited judicial review

Source reference: p. 12-13

Doctrine from Pubi Lombi v. State of Arunachal Pradesh, which holds that an administrative action is not invalidated merely because it was mooted by an elected representative, provided it is otherwise lawful

Source reference: p. 15
04

Reasoning

The Court found that two inquiry reports (19.05.2025 and 26.08.2025) confirmed the distance between the center points of the original village and "Khichan Vistar" was 1 km or more, satisfying the government's distance criteria

Source reference: p. 9-10

The Court reasoned that the Collector’s previous recommendation for cancellation was flawed as it relied on the adjacency of specific Khasras rather than the actual distance between village centers

Source reference: p. 10, para 7.1

Applying the Mala Ram precedent, the Court held that factual disputes regarding distance and population norms should not be entertained in writ jurisdiction

Source reference: p. 11, para 7.3

Regarding the allegation of "political influence," the Court determined that the representation by a ruling party leader merely brought the issue to the authorities' notice; since the resulting notification was supported by existing factual reports and statutory authority under Section 16 of the Act of 1956, it could not be termed mala fide

Source reference: p. 14-15
05

Holding

The Court dismissed the writ petition, holding that the petitioner failed to prove any violation of statutory norms or established arbitrariness

The Court ruled that the State has the sovereign power under Section 16 of the Rajasthan Land Revenue Act, 1956, to create revenue villages for better administration

Source reference: p. 13

The Court upheld the notification dated 13.12.2025, clarifying that a lawful administrative decision cannot be set aside simply because it originated from a political suggestion or because the State revisited a prior withdrawal

Source reference: p. 15-16

All stay applications and pending motions were disposed of accordingly

Source reference: p. 16
Rajasthan High Court

Original Court PDF

SATYANARAYAN SINGH RAJPUROHITvsSTATE OF RAJASTHAN

Rajasthan High Court · June 11, 2026

Click to open original judgment

Original judgment, available to read, download and summarize on LawLens.in

Click to open original judgment