Revisional Authority cannot entertain direct applications under Section 35 after denotification of consolidation proceedings.

In 1983, the Consolidation Officer, Kudra, ordered the land recorded in the name of the petitioner’s father, Dashrath Tiwari

The consolidation operation was finalized in 1981, and the area was denotified under Section 26A of the Bihar Consolidation of Holdings and Prevention of Fragmentation Act, 1956, on 25.06.2009

In 2010—27 years after the original order—Respondent No. 6 (Bipin Bihari Tiwari) filed a Revision Case (No. 209/2010) directly before the Director, Consolidation, Patna, seeking correction of records

The Director allowed the revision on 04.07.2011 based on an alleged 1970 Revenue Suit decree

The petitioner challenged this before the Bihar Land Tribunal (BLT), which dismissed the plea on 15.11.2019, directing the parties to Civil Court

The State also challenged the Director's order, claiming the land was "Anabad Bihar Sarkar" (Government land)

1. Whether the Director, Consolidation, could entertain a revision petition under Section 35 filed directly after the de-notification of the area under Section 26A of the Act

2. Whether a consolidation entry settled decades prior (1983) could be reopened via revision after inordinate delay without an impugned order from a lower authority

The court applied Section 35 of the Bihar Consolidation of Holdings and Prevention of Fragmentation Act, 1956, which grants the Director revisional powers to examine the correctness of orders passed by subordinate authorities

It relied on Bhanumati Devi v. State of Bihar (2011) and Mansaram v. S.P. Pathak (AIR 1983 SC 1239), establishing that power must be exercised within a reasonable time and matters settled decades ago cannot be reopened

Further, it applied Hari Narain Singh v. State of Bihar (1997) and Sher Singh v. Jt. Director of Consolidation (1978), holding that the Director cannot assume original jurisdiction or act as a de novo fact-finding authority if subordinate authorities acted within their jurisdiction

The Court found that the Director, Consolidation, fundamentally exceeded his jurisdiction by entertaining a revision petition filed directly in 2010 without any specific lower court order being impugned

The Court noted that since the land was denotified under Section 26A in 2009, the consolidation authorities generally lost jurisdiction over new disputes

Crucially, the Court highlighted the findings of a Three-Member Committee which suggested that the private respondent’s 2008-09 consolidation case was "antedated," "collusive," and "fraudulent"

The Court reasoned that an entry made in favor of the petitioner's father in 1983 attained finality; per Hari Narain Singh, Section 35 of the Act cannot be used to reopen disputes where no objections were filed at the appropriate statutory stages (Sections 10 or 12)

The delay of 27 years was deemed fatal to the maintainability of the revision

It held that the orders of the Bihar Land Tribunal (15.11.2019) and the Director, Consolidation (04.07.2011) were misconceived and bad in law

The Court quashed the Director’s order, effectively restoring the 1983 status quo in favor of the petitioner

The State's claim was rejected as it failed to challenge the 1983 allotment at the appropriate time

Both writ petitions were disposed of accordingly