Revenue authorities possess inherent power under Section 32 of MPLRC to execute their own orders.

The petitioner filed an application under Section 250 of the Madhya Pradesh Land Revenue Code (MPLRC), 1959, seeking restoration of possession of land (Survey Nos. 1822 and 1823) allegedly encroached upon by the 14th Battalion, Special Armed Force

Initially, the Tahsildar disposed of the application on 14.09.2022

On appeal, the Sub-Divisional Officer (SDO), Lashkar, set aside the Tahsildar's order on 10.06.2025 and remanded the case with a direction to dispose of the matter within 60 days

The petitioner approached the High Court under Article 226 of the Constitution, alleging that the Tahsildar failed to comply with the SDO’s time-bound remand order and sought a mandamus for its execution

1. Whether a writ petition under Article 226 is the appropriate remedy for seeking the enforcement/execution of an order passed by a Revenue Authority under the MPLRC.

The court applied Section 32 of the Madhya Pradesh Land Revenue Code, 1959, which preserves the inherent powers of Revenue Courts to make orders necessary for the ends of justice or to prevent abuse of process

It specifically relied on the precedent *Dakho Bai vs. State of M.P. and others, 2015 (3) MPLJ 202*, which established that while the Code lacks an independent execution provision, a Revenue Authority can exercise inherent powers under Section 32 to execute its own orders

The Court observed that the primary relief sought was the enforcement of the SDO’s remand order dated 10.06.2025

Following the principle laid down in *Dakho Bai*, the Court reasoned that the petitioner has an efficacious alternative remedy under the MPLRC itself

Specifically, since the Code does not have a dedicated execution chapter, Section 32 grants Revenue Courts the inherent jurisdiction to implement and execute their orders to ensure complete justice

The Court found that the petitioner had not yet invoked this statutory remedy before the relevant revenue authority before approaching the High Court

The Court directed that the petitioner is at liberty to seek execution of the SDO’s order by invoking the inherent powers of the revenue authority under Section 32 of the Code

No costs were awarded, and all pending applications were closed