Madhya Pradesh High Court
Administrative and Public LawProperty and Real Estate Law

Participation and consideration of objections defeat a natural-justice challenge to demarcation orders.

Jitendra Agnihotri vs Sharda Sharan Agnihotri

Madhya Pradesh High CourtJUDGMENT: September 28, 20262 MIN READSOURCE JUDGMENT
Participation and consideration of objections defeat a natural-justice challenge to demarcation orders.. Jitendra Agnihotri vs Sharda Sharan Agnihotri. Madhya Pradesh High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

Respondent No. 1 sought demarcation under Section 129 of the Madhya Pradesh Land Revenue Code, 1959, of specified lands at Village Bamhouri, District Satna.

Source reference: para. 2

The Revenue Inspector and Patwari conducted the demarcation on 11 November 2024. The petitioners participated and filed objections, including objections concerning the use of the original settlement map and the correlation of the field position with revenue records.

Source reference: paras. 1–2, 6

The Tehsildar accepted the demarcation report by order dated 10 January 2025; the Sub-Divisional Officer dismissed the petitioners’ appeal on 16 March 2026. A consequential notice was issued on 18 May 2026. The petitioners challenged these actions under Article 226 of the Constitution

Source reference: paras. 1–2, 6
02

Issues

Whether the petitioners were denied an opportunity to present their case in the demarcation proceedings

Source reference: paras. 2–3, 6

Whether the Tehsildar’s and Sub-Divisional Officer’s orders disclosed an illegality warranting interference under Article 226 of the Constitution

Source reference: para. 6
03

Law Applied

Section 129 of the Madhya Pradesh Land Revenue Code, 1959, provides the statutory basis for revenue demarcation proceedings

Source reference: para. 2

The Court applied the principle that a party given notice and an opportunity to participate, whose objections are considered by the competent authorities, cannot establish a denial of hearing on those facts

Source reference: para. 6

It further held that interference under Article 226 was not warranted absent illegality in the impugned orders

Source reference: para. 6
04

Reasoning

The Court found that the petitioners had notice of the demarcation, participated in it, and submitted objections.

Source reference: para. 6

It also found that the Tehsildar considered the demarcation report and that the appellate authority examined the matter before dismissing the appeal. On that record, the petitioners’ claim that they had been denied an opportunity to present their case was untenable, and the Court found no illegality justifying writ interference

Source reference: para. 6
05

Holding

The Court held that the petitioners had been afforded an opportunity to participate and that no ground for interference under Article 226 was established.

It dismissed the writ petition as without merit

Source reference: paras. 6–7
06

Acts & Sections Cited

2 provisions across 1 statute referred to in this judgment. Each provision opens on LawLens.

MP Land Revenue Code 19592

Madhya Pradesh High Court

Original Court PDF

Jitendra AgnihotrivsSharda Sharan Agnihotri

Madhya Pradesh High Court · September 28, 2026

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