Madhya Pradesh High Court
Administrative and Public LawProperty and Real Estate Law

Revenue authority must decide demarcation objections by a reasoned order after hearing all concerned parties.

Mrs. Uma Singhal vs The State Of Madhya Pradesh

Madhya Pradesh High CourtJUDGMENT: August 12, 20262 MIN READSOURCE JUDGMENT
Revenue authority must decide demarcation objections by a reasoned order after hearing all concerned parties.. Mrs. Uma Singhal vs The State Of Madhya Pradesh. Madhya Pradesh High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner and her sister-in-law purchased 0.150 hectare of land in Survey No. 1180/2, Village Naipari, Tehsil Kailaras, District Morena, through a registered sale deed.

Source reference: p.1

The petitioner subsequently purchased an additional 0.059 hectare in the same survey number through a registered sale deed dated 06.09.2021.

Source reference: p.1

The transactions were allegedly made after obtaining the Collector’s permission, and the purchasers’ names were mutated in the revenue records.

Source reference: p.1

The land was later diverted for non-agricultural use by order dated 08.05.2025, after which the petitioner claimed possession and erected fencing over it.

Source reference: p.1

Respondent Nos. 6 and 7 purchased the remaining 6.15 hectares of the survey number on 11.04.2025.

Source reference: pp.1–2

The petitioner alleged that an erroneous demarcation report was prepared in collusion with revenue officials, leading to partition proceedings affecting her land.

Source reference: pp.1–2

She submitted objections and complaints before the competent authorities, which remained undecided.

Source reference: pp.1–2

The State did not oppose a direction requiring the competent revenue authority to decide the petitioner’s objections after hearing all concerned parties.

Source reference: p.3
02

Issues

Whether the competent revenue authority should be directed to consider and decide the petitioner’s objections to the disputed demarcation and consequential revenue proceedings in accordance with law.

Source reference: p.3

Whether such decision should be made after consideration of the relevant revenue records, hearing all concerned parties, and by passing a reasoned and speaking order.

Source reference: p.3
03

Law Applied

The Court exercised its jurisdiction under Article 226 of the Constitution of India to issue an appropriate direction to a public authority where the petitioner’s objections had not been considered.

Source reference: pp.1, 3

It applied the principles of natural justice, requiring that all concerned parties be afforded an opportunity of hearing, and the administrative/revenue authority pass a reasoned and speaking order based on the relevant records.

Source reference: pp.1, 3

The Court did not adjudicate the parties’ competing claims regarding title, possession, demarcation, or partition on merits.

Source reference: pp.1, 3
04

Reasoning

The petitioner’s principal grievance was not finally adjudicated by the Court; rather, it concerned the alleged failure of the competent revenue authority to decide her objections against the demarcation and related proceedings.

Source reference: pp.1–3

Since the State consented to a direction for consideration of the objections, and the grievance could appropriately be addressed by the revenue authority, the Court considered it unnecessary to examine the merits of the disputed land claims.

Source reference: p.3

It therefore required the Tehsildar to examine the relevant revenue records, hear all concerned parties, and issue a reasoned and speaking decision, thereby safeguarding procedural fairness without expressing any opinion on the substantive dispute.

Source reference: p.3
05

Holding

The writ petition was disposed of without entering into the merits.

Respondent No. 4, the Tehsildar, Kailaras, District Morena, was directed to consider and decide the petitioner’s objections contained in Annexure P/7 in accordance with law, after examining the relevant revenue records and providing an opportunity of hearing to all concerned parties.

Source reference: p.3

The decision was to be made by a reasoned and speaking order, preferably within four weeks from receipt of a certified copy of the order.

Source reference: p.3
Madhya Pradesh High Court

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Mrs. Uma SinghalvsThe State Of Madhya Pradesh

Madhya Pradesh High Court · August 12, 2026

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