Revenue Officer Must Reconsider Section 14T(3) Proceedings in Accordance with the Appellate Remand.

A proceeding under Section 14T(3) of the West Bengal Land Reforms Act, 1955 (“the 1955 Act”) had been initiated against the petitioner. The notice underlying that proceeding was set aside by the High Court in an earlier writ petition.

The petitioner later filed returns reflecting the relevant position and complained that no fresh proceeding under Section 14T(3) had been completed.

In 2015, the Land Reforms and Tenancy Tribunal directed the District Land and Land Reforms Officer, Paschim Medinipur, to take steps for rehearing Case No. 19 of 1977 under Section 14T(7) and pass an order after hearing those concerned.

The Tribunal subsequently recorded that its direction had been complied with when Case No. 19 of 1977 was concluded.

On appeal, however, the Additional District Magistrate and District Land and Land Reforms Officer remanded the matter to the Block Land and Land Reforms Officer (“BL&LRO”) for fresh disposal according to law.

The petitioner sought a direction requiring the BL&LRO to complete the proceeding afresh.

1. Whether the Tribunal’s orders dated 27 August 2015 and 30 November 2023 warranted interference.

2. Whether the BL&LRO should be directed to dispose of the matter afresh under Section 14T(3) in accordance with the appellate authority’s remand order.

Section 14T(3) of the 1955 Act governed the proceeding to be considered afresh by the BL&LRO, while Section 14T(7) was relevant to the appeal and the earlier Tribunal direction concerning Case No. 19 of 1977.

The appellate authority’s order dated 8 November 2023 remanded the matter to the BL&LRO for fresh disposal in accordance with law; the High Court directed compliance with that order after providing the petitioner and interested parties an opportunity to be heard.

No judicial precedent was cited.

The Court found that the dispute had been remitted to the BL&LRO for fresh adjudication under the appellate authority’s order, and that the matter remained pending before that officer.

Since the Tribunal’s orders did not warrant interference, the Court declined to disturb them; it instead directed the BL&LRO to complete the pending proceeding in accordance with the appellate remand and after hearing the petitioner and interested parties.

It disposed of the writ petition by directing the respondent BL&LRO, Garhbeta-II, to decide the proceeding under Section 14T(3) in accordance with the appellate authority’s order dated 8 November 2023, after giving the petitioner and all interested parties an opportunity of hearing, as expeditiously as possible and by 24 December 2026.

No order was made as to costs.