Revenue authorities must decide pending statutory proceedings within a reasonable, legally justified period.

The petitioner had filed an application seeking permission under Section 165(6) of the Chhattisgarh Land Revenue Code, 1959, before the Collector, Rajnandgaon.

The proceedings had allegedly been considered but remained pending for passing of a final order for a considerable period.

The petitioner therefore sought a writ directing the Collector to conclude the pending revenue proceedings and pass a reasoned order within a fixed period.

The State submitted that the competent authority would decide the application in accordance with law within the period stipulated by the Court.

The order contains an apparent discrepancy in the revenue case number and year: the prayer refers to Revenue Case No. 202511090100028/A-21(1), Year 2025–2026, whereas the operative direction refers to Revenue Case No. 202507090100021/A-21(1), Year 2024–2025.

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

Whether statutory and quasi-judicial revenue proceedings may remain pending indefinitely without a lawful or justifiable reason.

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 authorities are under a duty to decide applications and proceedings within a reasonable period and cannot keep them pending indefinitely or in a prolonged and arbitrary manner without lawful justification.

The Court also recognised that, while directing expeditious disposal, it must not express any opinion on the merits of the pending statutory application.

The petitioner demonstrated that his statutory application had remained pending before the competent authority despite the proceedings having been considered.

Since the State did not oppose disposal and undertook that the authority would decide the matter in accordance with law, the Court found it appropriate to exercise its writ jurisdiction to prevent indefinite delay.

The direction was limited to requiring a reasoned and speaking decision and did not determine the petitioner’s substantive entitlement under Section 165(6).

The Court accordingly required the Collector to decide the matter independently on its merits and in accordance with the applicable law.

The Court clarified that it had expressed no opinion on the merits of the application.