Revenue authorities must promptly decide heard statutory proceedings and cannot keep them pending indefinitely.

The petitioner, Jaipal, had an application pending before the Collector, Rajnandgaon, in Revenue Case No. 202507090100021/A-21(1), Year 2024–2025, seeking permission under Section 165(6) of the Chhattisgarh Land Revenue Code, 1959.

Although the proceedings had been heard, the competent authority had not passed a final order for a considerable period, allegedly causing prejudice to the petitioner.

The petitioner therefore filed the present writ petition seeking a direction to the Collector to conclude the proceedings and pass a reasoned order within a specified time.

The State did not oppose the request and submitted that the competent authority would decide the pending application in accordance with law within the time stipulated by the Court.

Whether the High Court should issue a time-bound direction to the Collector to conclude the pending proceedings under Section 165(6) of the Chhattisgarh Land Revenue Code, 1959, and pass a final, reasoned order.

Whether statutory or quasi-judicial revenue proceedings, particularly after conclusion of hearing, may remain pending indefinitely without lawful justification.

The Court applied Section 165(6) of the Chhattisgarh Land Revenue Code, 1959, governing the permission sought by the petitioner.

It further applied the principle that revenue authorities exercising statutory or quasi-judicial jurisdiction are obligated to decide applications and proceedings within a reasonable time and cannot keep matters pending indefinitely or in a prolonged and arbitrary manner, particularly after the matter has been heard and in the absence of lawful justification.

The Court also recognised that a direction to decide a pending proceeding does not involve adjudication on the merits of the underlying claim.

The Court noted that the petitioner’s application had already been heard but that no final order had been passed despite prolonged pendency.

Since the grievance concerned administrative and quasi-judicial delay, rather than the merits of the claim under Section 165(6), the Court considered it appropriate to issue a time-bound direction.

The State’s submission that the competent authority would decide the matter in accordance with law further supported such a direction.

Accordingly, without expressing any opinion on the petitioner’s entitlement to permission, the Court required the Collector to conclude the proceedings and issue a speaking order within the prescribed period.

The Court clarified that it had not expressed any opinion on the merits and that the competent authority must decide the matter independently.