Reorganization of Gram Panchayats based on irrational distance metrics and ignored contiguity is manifestly arbitrary and unsustainable.

The Petitioners (a youth club and a Mahila Mandal) challenged a notification dated 27.01.2026, which excluded Village Manlog-Badog from Gram Panchayat (GP) Hanuman Badog and included it in GP Darlaghat

On 18.12.2025, the State invited objections to the proposed reorganization.

Petitioners filed objections on 30.12.2025, arguing that Manlog-Badog and Hanuman Badog are contiguous (2–3 km apart), whereas Darlaghat is significantly farther (6–7 km) and residents are socially and economically interwoven with Hanuman Badog.

Despite these objections, the State issued the final notification.

The State justified the move based on 2013 and 2024 resolutions from some villagers claiming the distance to Hanuman Badog was 14 km by road.

Whether the reorganization and inclusion of Village Manlog-Badog into GP Darlaghat was based on arbitrary and incorrect factual findings regarding geographical distance and administrative convenience

Whether the Court can exercise judicial review over delimitation and reorganization processes during the subsistence of an election schedule

The Court applied Section 3(2) of the Himachal Pradesh Panchayati Raj Act, 1994, which empowers the government to alter or merge Panchayat areas after inviting public objections.

It also relied on the Supreme Court’s ruling in Kishorchandra Chhhanganlal Rathod v. Union of India (2024), which clarifies that while Article 329 (and 243-O/243-ZG) restricts judicial scrutiny of delimitation to ensure elections are not indefinitely delayed, it does not impose a total bar on judicial review if the action is "manifestly arbitrary" or "irreconcilable to constitutional values".

The Court found the State’s reliance on a "14 km distance" between Manlog-Badog and Hanuman Badog to be irrational.

Evidence showed the villages are contiguous, with a 2.5 km direct Panchayat road, whereas the State’s 12.82 km figure was calculated via a circuitous route.

The Court noted the State ignored the "on-foot" distance of 2–3 km, which is crucial for local governance.

Furthermore, the move was demographically illogical: the State added a small village (pop. 280) to a large Panchayat (GP Darlaghat, pop. 4500) while removing it from a smaller one (GP Hanuman Badog, pop. 1500) where it was naturally integrated.

The Court determined that the State’s decision, based on decade-old requests and incorrect distance metrics, ignored current infrastructure and public interest.

Under the Kishorchandra precedent, the Court held that since the delimitation process was still ongoing and not finalized, judicial intervention was warranted to correct a "manifestly arbitrary" administrative act.

It quashed the notification dated 27.01.2026 (inclusion in GP Darlaghat) and the subsequent delimitation notification dated 02.02.2026.

The Respondents were directed to issue a fresh notification restoring Manlog-Badog to GP Hanuman Badog within five days.

Lastly, the Court cautioned the State against undertaking "large scale reorganization" in haste near election deadlines, as such "delaying tactics" lead to procedural lacunae.