Kotwari service land is non-transferable, and no title can be acquired through its sale.

The petitioner alleged that respondent No. 7 had purchased Kotwari service land, which she contended was non-transferable, and complained that the authorities had not acted on the alleged transfer and ongoing construction

The State submitted that the Collector was conducting an inquiry into whether the land had been sold to respondent No. 7 and stated that appropriate action would follow if the sale were established

The petitioner accepted that submission but sought a direction to complete the inquiry within a fixed period

Whether the authorities should inquire into the alleged sale of Kotwari land to respondent No. 7 and take appropriate action if the transfer is established

Whether the inquiry should be completed within a stipulated period

The Court relied on the Full Bench decision in Gajendra Das v. State of Chhattisgarh, W.P.(C) No. 1571 of 2020, decided on 23 July 2026, as stating that Kotwari land cannot be alienated and no title can be acquired on the basis of such land; if such land has been sold, it is to be retained by the State in accordance with law

Although the petitioner sought action under Section 183 of the M.P./C.G. Land Revenue Code, 1959, the Court did not independently interpret or apply that provision

The Court did not determine whether respondent No. 7 had in fact purchased Kotwari land.

In light of the State’s submission that the Collector’s inquiry was ongoing and the Full Bench ruling on non-transferability, it left the factual determination and consequential action to the authorities.

It directed that the inquiry and appropriate orders be completed within three months, including ensuring that the land remains with the State if the alleged sale is established

If the land is found to be Kotwari land sold to respondent No. 7, the authorities must ensure its retention by the State in accordance with law

The Court did not itself declare the transaction void or grant the other substantive reliefs sought.