Revisional authorities must address material objections in reasoned orders before setting aside long-standing revenue orders.

The petitioner and respondent, real brothers, disputed the partition and revenue treatment of agricultural land inherited from their late father. The petitioner relied on a Tahsildar’s order dated 16.08.1999 concerning partition.

The Collector, exercising revisional jurisdiction under Section 50 of the Madhya Pradesh Land Revenue Code, 1959, set aside that order by order dated 30.09.2025. The petitioner challenged the Collector’s decision, raising, among other grounds, the maintainability of the proceedings, the effect of an SDO order dated 22.07.2025, and the delay in questioning the 1999 order. The respondent disputed the existence and legal validity of the alleged partition and challenged the jurisdictional basis of the 1999 order.

1. Whether the Collector’s order setting aside the Tahsildar’s 16.08.1999 order adequately considered the parties’ material objections and gave sufficient reasons

2. Whether the proceedings required fresh consideration of the objections concerning maintainability, the SDO’s order dated 22.07.2025, delay, and the validity and jurisdictional basis of the 1999 order

Authorities exercising statutory or quasi-judicial powers must consider relevant facts, applicable law, and the parties’ submissions, and give reasons for decisions affecting their rights; reasons guard against arbitrary action and enable judicial review

In Kranti Associates Pvt. Ltd. v. Masood Ahmed Khan, (2010) 9 SCC 496, the Supreme Court affirmed that quasi-judicial authorities must record cogent reasons and that reasoned decisions are integral to fairness, transparency, and effective judicial review

Section 50 of the Madhya Pradesh Land Revenue Code, 1959, was relied on by the respondent as the basis for the Collector’s revisional jurisdiction

The Court found that the Collector’s order did not satisfactorily address material questions, including whether the proceedings were maintainable, the legal effect of the SDO’s 22.07.2025 order, whether the delay in challenging the 1999 order was legally sustainable, and whether the earlier order was supported by a valid partition and jurisdictional authority.

Because these issues went to the root of the dispute, a bare conclusion setting aside the earlier order did not meet the requirement of a reasoned decision. The Court therefore set aside the Collector’s order and remitted the matter without determining the merits of the parties’ claims.

The Collector must address the specified objections, afford both parties an opportunity of hearing, and pass a reasoned order within six weeks of receiving a certified copy of the High Court’s order. All questions on the merits were left open.