MP HC Quashes SDO’s Rejection Of Land Buyer’s Demarcation Objections, Orders Fresh Decision Within 90 Days

The petitioner challenged an order of the Sub-Divisional Officer (SDO) dated 7 July 2026, which rejected objections to a demarcation of land in Khasra No. 71/1.

The demarcation followed an earlier order directing correction of the revenue map; the petitioner had objected to the demarcation report and the Tehsildar had rejected those objections.

The petitioner contended that its detailed objections—including that the map-correction order had not been implemented and was subject to further proceedings—were not addressed by the SDO.

The respondents maintained that the SDO had considered the objections and the record.

Section 129(5) of the Madhya Pradesh Land Revenue Code (MPLRC) provides a means to raise objections in demarcation proceedings.

A quasi-judicial authority must consider the parties’ material objections and give clear, cogent reasons for its conclusions; reasons support fairness, constrain arbitrary decision-making, and enable judicial review.

The Court relied on Kranti Associates (P) Ltd. v. Masood Ahmed Khan, (2010) 9 SCC 496, which affirmed these requirements for judicial and quasi-judicial decisions.

The SDO’s order recited that the record had been examined, the objections heard, and the demarcation procedure followed, but did not explain why the petitioner’s specific objections were rejected.

Because the petitioner’s detailed objections were reflected in the proceedings yet the order supplied no reasons addressing them, the Court found no demonstrable application of mind.

The general statement that no error was apparent could not satisfy the requirement for a reasoned quasi-judicial decision.

The matter was remanded to the SDO to reconsider the matter and the petitioner’s objections, hear all affected parties, and pass a fresh order within 90 days.

The parties were left at liberty to raise all arguments before the SDO.

The writ petition was allowed and disposed of.