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. 2On 22.03.2025, the village "Khichan Vistar" was created
Source reference: p. 3Following 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. 4-5Based on this, the Collector recommended cancellation, and the State issued a notification on 17.11.2025 withdrawing the village’s creation
Source reference: p. 5Subsequently, 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. 6Issues
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 32. 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 3.23. 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State is empowered to issue a fresh notification for the creation of a village after a previous notification had been withdrawn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 8.1Law 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. 12Principle 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. 12-13Doctrine 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. 15Reasoning
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. 9-10The 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 7.1Applying 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 7.3Regarding 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. 14-15Holding
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. 13The 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. 15-16All stay applications and pending motions were disposed of accordingly
Source reference: p. 16Original Court PDF
SATYANARAYAN SINGH RAJPUROHITvsSTATE OF RAJASTHAN
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