Non-owner claiming rights through unregistered agreement to sell cannot challenge land tenure conversion orders.

The appellant/petitioner filed a Regular Civil Suit (No. 382 of 2012) seeking a declaration and permanent injunction against respondents No. 3 to 15 based on an unregistered agreement to sell

The suit was dismissed on 18.07.2016, and this dismissal was eventually upheld by the Hon’ble Apex Court

Despite this, the appellant challenged an order dated 17.02.2021 passed by the Collector, Vadodara, which allowed the conversion of the subject land from "New Tenure" to "Old Tenure"

The Gujarat Revenue Tribunal rejected the appellant’s revision application on 19.06.2025, and a learned Single Judge subsequently dismissed the writ petition on 12.01.2026, holding the appellant had no standing

1. Whether a party who has lost a civil suit for declaration of rights based on an unregistered agreement to sell maintains the locus standi to challenge revenue orders regarding land tenure conversion

2. Whether the Collector’s order for land conversion was illegal due to the pendency of litigation regarding the underlying property

The court applied the principle of Locus Standi in revenue proceedings, establishing that an "outsider" with no established legal interest in the property cannot maintain a challenge against administrative orders passed in favor of the lawful owners

It also strictly interpreted the legal weight of an unregistered agreement to sell under the Registration Act and Transfer of Property Act, implying such documents do not confer ownership or enforceable rights sufficient to interfere with the State's revenue functions once the civil remedy is exhausted

The Court reasoned that the appellant’s claim was entirely contingent upon an unregistered agreement to sell, a document that had already failed to secure him any relief in civil court

Since the Civil Suit was dismissed and the judgment attained finality via the Supreme Court, the appellant has no subsisting legal claim or right pertaining to the land

Consequently, the Court found the appellant to be an "outsider" to the revenue proceedings between the State and the actual owners

The appellant's reliance on Shree Vinayak Buildcon v. Special Secretary (Appeals) was rejected as inapplicable to these facts

The Court held that a third party with no title cannot be permitted to obstruct the conversion of land tenure conducted by competent authorities

The Court dismissed the Letters Patent Appeal, affirming the judgment of the learned Single Judge and the Gujarat Revenue Tribunal