High Court Refuses to Condone Decadelong Delay in Challenging Revenue Orders Without Sufficient Cause.

Respondent No. 4 filed an application under Section 250 of the M.P. Land Revenue Code alleging illegal possession of land (Survey Nos. 88, 100, 136 min, and 142 min) by the petitioners.

On 05.12.2016, the Tehsildar, Bhitarwar, held the petitioners to be unauthorized occupants and ordered their removal.

The petitioners’ subsequent appeals were dismissed by the Sub-Divisional Officer on 30.03.2017 and the Additional Commissioner on 20.09.2017.

The petitioners approached the High Court in 2026, nearly ten years after the final revenue order, claiming they were rustic villagers who were misled by assurances from the private respondent regarding a sale deed.

1. Whether the writ petition is liable to be dismissed on the grounds of inordinate delay and laches.

2. Whether the petitioners’ status as "rustic villagers" and alleged verbal assurances of a sale deed constitute "sufficient cause" to condone a ten-year delay in filing.

The court applied the equitable principles governing Article 226 of the Constitution of India, emphasizing that extraordinary jurisdiction is discretionary and cannot be invoked by a litigant guilty of gross delay and laches.

The court further relied on the principle of finality of judicial and quasi-judicial proceedings, which holds that stale claims should not be entertained if they prejudice accrued rights of the opposing party.

The court also assessed Section 250 of the M.P. Land Revenue Code regarding the summary eviction of unauthorized occupants.

The Court rejected the petitioners’ explanation for the ten-year delay, noting that they had already successfully navigated the legal system through two rounds of statutory appeals, which contradicted their claim of being "rustic villagers" ignorant of legal procedures.

The Court reasoned that mere assertions of verbal assurances from a respondent do not constitute a "cogent, sufficient, or convincing reason" for a decade of inaction.

Applying the doctrine of laches, the Court determined that reviving a matter decided in 2017 would cause significant prejudice to the respondents and undermine the legal finality of the revenue authorities' orders.

The Court answered the issues by stating that the explanation offered did not constitute sufficient cause for condonation.

Consequently, the High Court dismissed the writ petition without costs, affirming the orders of the revenue authorities and declining to exercise its discretionary jurisdiction under Article 226.