Pendency of a civil suit does not bar summary eviction proceedings under Section 250 MP Land Revenue Code.

The Appellant, a developer of a housing colony, challenged a Common Final Order dated 04.02.2026 passed by a Single Judge, which dismissed three writ petitions.

The dispute originated when Respondent No. 6 sought map correction for Khasra No. 227, alleging a 3.110-hectare deficit between textual records and the physical village map.

Revenue authorities allowed the map correction based on a Superintendent of Land Records (SLR) Report.

Subsequent field demarcation under Section 129 of the M.P. Land Revenue Code (MPLRC) indicated the Appellant was in possession of Respondent No. 6's land, leading to summary eviction proceedings under Section 250.

The Appellant argued that revenue proceedings should be stayed pending a civil suit for title (RCS No. 132A/2022).

1. Whether a text-to-map discrepancy in land records can be corrected for a single sub-holder based on an official SLR report without a block-wide inquiry.

2. Whether the pendency of a substantive civil suit regarding title operates as a bar to summary eviction proceedings under Section 250 of the MPLRC.

3. Whether the signature of a representative on a demarcation Panchnama carries evidentiary weight regarding procedural compliance.

The court primarily applied the Madhya Pradesh Land Revenue Code, 1959, specifically Section 107 (map correction), Section 115 (rectification of errors), Section 129 (demarcation), and Section 250 (summary eviction).

It applied the principle that official reports from state agencies (SLR) carry inherent evidentiary weight, shifting the onus of proof to the contesting party.

It further relied on the doctrine that summary revenue jurisdiction is not automatically ousted by the mere filing of a civil suit unless a specific interim injunction is granted by the Civil Court.

The Court reasoned that the SDO acted within jurisdiction by relying on the SLR Report, as the Appellant failed to produce any counter-scientific or documentary evidence despite multiple opportunities after remand.

Moving to the demarcation process, the Court found that the presence and signature of the Appellant’s representative on the Panchnama, coupled with proper notices, satisfied procedural mandates under Section 129.

On the conflict between civil and revenue jurisdictions, the Court held that revenue authorities are statutory custodians of immediate possession; in the absence of a temporary injunction from the Civil Court, the Naib Tehsildar was duty-bound to proceed with Section 250 based on the confirmed demarcation.

Finally, the Court noted that Town & Country Planning approvals do not validate possession beyond the area for which the holder has clear legal title.

The Court vacated all interim orders and imposed exemplary costs of Rs. 1,00,000/- on the Appellant for suppression of material facts, specifically noting that the Appellant’s application for injunction had already been rejected by the Civil and Appellate Courts.