Judicial review of Lambardar appointments is limited absent illegality, perversity, or non-consideration of statutory criteria.

A post of Scheduled Caste Lambardar in Village Mehna, Tehsil Malout, District Sri Muktsar Sahib, was created on 25.11.2016.

The District Collector appointed respondent No. 4, Arvel Singh, to the post.

The appellant’s appeal and revision were dismissed by the Commissioner and the Financial Commissioner on 27.07.2022 and 09.11.2023, respectively.

The appellant’s writ petition challenging those orders was dismissed by the learned Single Judge on 22.12.2023, who upheld Arvel Singh’s appointment and directed his appointment as Lambardar.

The appellant challenged the Single Judge’s decision in the present intra-court appeal, asserting that he was younger, better educated, recommended by the Gram Panchayat, and had no criminal antecedents.

Arvel Singh had served in the Indian Army for approximately 30/31 years.

Whether the learned Single Judge erred in upholding the revenue authorities’ appointment of Arvel Singh as Lambardar despite the appellant’s asserted advantages of younger age, educational qualifications, Gram Panchayat recommendation, and clean antecedents.

Whether the concurrent findings and choice of the District Collector could be interfered with in judicial review absent patent perversity, illegality, arbitrariness, or non-consideration of the statutory criteria under Rule 15 of the Punjab Land Revenue Rules, 1909.

The Court applied Rule 15 of the Punjab Land Revenue Rules, 1909, which requires consideration, inter alia, of hereditary claims, property sufficient to secure land-revenue recovery, services rendered to the State, personal influence, character, ability, freedom from indebtedness, the strength and importance of the relevant community, and services rendered in national movements.

Relying on Mahavir Singh v. Khiali Ram, 2009 (3) SCC 439, the Court held that judicial review does not permit reassessment or comparison of the relative merits of Lambardar candidates as an appellate court, but interference is justified where the decision-making process is vitiated by patent perversity, illegality, arbitrariness, or non-consideration of relevant statutory criteria.

Under Ishwar Singh v. Satbir Singh, 2009 (9) SCC 392, factors such as education, age, experience in the Lambardari system, landholding, character, ability, and freedom from indebtedness must be considered and weighed in determining suitability and comparative merit.

The choice of the District Collector, as the district’s overall administrative authority, is not to be interfered with unless affected by illegality, perversity, or another material infirmity.

The Court found that the District Collector, Commissioner, and Financial Commissioner had concurrently considered the relevant circumstances and supported their conclusions with cogent reasons.

The appellant’s younger age, educational qualifications, Panchayat recommendation, and absence of criminal antecedents did not establish that the authorities had ignored the statutory criteria or that their decision was perverse or arbitrary.

Conversely, Arvel Singh’s approximately 30/31 years of service in the Army constituted a relevant circumstance deserving consideration under the framework governing appointment to the post.

Since the appellant sought a reassessment of comparative merit rather than demonstrating a jurisdictional error, illegality, perversity, or material infirmity, the limited scope of judicial review was not satisfied.

Finding no infirmity, illegality, or perversity in the impugned judgment, the Court dismissed the appeal.

Any pending miscellaneous applications were also disposed of.