Revenue authorities must decide pending statutory proceedings expeditiously and by passing reasoned, speaking orders.

The petitioner filed an application seeking permission under Section 165(6) of the Chhattisgarh Land Revenue Code, 1959, which was pending before the Collector, Rajnandgaon, in Revenue Case No. 202510090100004/A-21(1).

The petitioner alleged that the proceedings had already been considered but remained pending for passing of a final order for a considerable period. He therefore approached the High Court seeking a writ of mandamus directing the Collector to decide the proceedings within a fixed period.

The State counsel, on instructions, submitted that the competent authority would decide the pending application in accordance with law within the time stipulated by the Court.

1. Whether the High Court should issue a time-bound direction to the Collector to decide the petitioner’s pending statutory application under Section 165(6) of the Chhattisgarh Land Revenue Code, 1959.

2. Whether the Court could direct expeditious disposal without expressing any opinion on the merits of the petitioner’s application.

The Court applied Section 165(6) of the Chhattisgarh Land Revenue Code, 1959, governing the petitioner’s application for permission.

It further applied the principle that statutory and quasi-judicial proceedings cannot remain pending indefinitely and must be decided within a reasonable period, through a reasoned and speaking order and in accordance with law.

The Court also recognised that a direction for expeditious disposal does not amount to adjudication of the merits of the underlying claim.

The Court found that the petitioner’s statutory proceedings had remained undecided for an extended period and that such indefinite pendency was inconsistent with the obligation of revenue authorities exercising statutory and quasi-judicial jurisdiction.

Since the State did not oppose a time-bound decision and undertook that the competent authority would decide the matter in accordance with law, the Court considered it appropriate to issue a limited mandamus.

The direction was confined to deciding the pending proceedings and did not determine whether permission under Section 165(6) should ultimately be granted or refused.

The Collector, Rajnandgaon, was directed to decide Revenue Case No. 202510090100004/A-21(1), concerning the petitioner’s application under Section 165(6) of the Chhattisgarh Land Revenue Code, 1959, within 20 days from receipt of a copy of the order, by passing a reasoned and speaking order strictly in accordance with law.

The Court clarified that the competent authority must independently consider the application on its merits and that statutory proceedings should not be kept pending indefinitely.