Facts
The petitioners filed a writ petition challenging the orders dated 02.06.2026 and 11.08.2025 passed by the Commissioner, Sarguja Division (Respondent No. 2).
Source reference: p. 1-2These orders arose from a revenue dispute where the Collector, Manendragarh, had previously declared certain land maps unauthorized, ordered the preparation of new maps, and directed the initiation of Departmental Enquiries and FIRs against revenue officials, including the Tahsildar (Respondent No. 4).
Source reference: para. 2/p. 3-4The aggrieved revenue officials appealed to the Commissioner, who stayed the Collector's directions.
Source reference: para. 2/p. 4-5The petitioners, having been impleaded as parties in the appellate proceedings, sought to vacate the stay, which the Commissioner refused.
Source reference: para. 2/p. 4-5The petitioners subsequently approached the High Court seeking a writ of certiorari to set aside the Commissioner's orders.
Source reference: p. 2Issues
1. Whether the High Court should interfere with an interim stay order passed by the Commissioner in a pending revenue appeal when the matter is squarely covered by a previous coordinate bench decision.
Source reference: p. 2-3 / para. 42. Whether the Commissioner has the statutory authority to stay the operation of a Collector's order pending final adjudication of a revenue dispute.
Source reference: para. 2 (citing para. 7 of preceding judgment) / p. 6Law Applied
Section 44 and Section 52 of the Chhattisgarh Land Revenue Code, which empower the Commissioner, as the superior appellate authority, to hear appeals and stay the effect and operation of orders passed by the Collector.
Source reference: para. 2 (citing para. 7 of preceding judgment) / p. 6The principle of judicial consistency, noting that the issue was squarely covered by the precedent set in Satpal Singh Saluja and another vs. State of Chhattisgarh and others (WPC No. 2913 of 2026).
Source reference: p. 2 / para. 2Reasoning
The Court observed that the grievance and relief sought in the present petition were identical to those in WPC No. 2913 of 2026.
Source reference: p. 2, 7Applying the reasoning from the cited precedent, the Court noted that the Collector’s findings regarding the illegality of the maps were administrative in nature and required verification by the Commissioner.
Source reference: para. 2/p. 5-6The Court reasoned that the Collector's directions for FIRs and disciplinary actions were "premature" until the Commissioner reached a final conclusion on whether the maps were indeed prepared with malafide intent.
Source reference: para. 2/p. 6The Court held that the Commissioner acted within his jurisdiction under the Chhattisgarh Land Revenue Code to grant a stay, and such a stay should not be vacated simply because it involved a direction to register an FIR.
Source reference: para. 2/p. 6Since the matter is still pending final adjudication before the Commissioner, the Court found no grounds for interference at this interim stage.
Source reference: para. 2/p. 7Holding
The Court dismissed the writ petition, holding that there was no fit case for interference with the impugned orders while the matter remained pending before the appellate authority.
The Court answered the issues by confirming the Commissioner's power to stay lower orders under the Land Revenue Code.
Source reference: para. 2/p. 6The petition was disposed of in terms of the order passed in WPC No. 2913 of 2026, reserving liberty to the petitioners to pursue their case before the Commissioner in accordance with the law.
Source reference: p. 7No costs were awarded.
Source reference: p. 8Original Court PDF
SATPAL SINGH SALUJAvsSTATE OF CHHATTISGARH
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