Sanction for review under Section 51 of MPLRC requires mandatory prior notice to affected parties.

The petitioners challenged an order dated 02.03.2026 passed by the Additional Collector, District Neemuch.

Earlier, an application for mutation by respondents 8 and 9 was rejected by the Tehsildar, and that rejection was upheld by the Sub Divisional Officer (SDO) on 10.09.2025.

On 25.02.2026, the SDO sought sanction from the Additional Collector to review the order dated 10.09.2025.

The Additional Collector granted this sanction on 02.03.2026 without providing the petitioners an opportunity to be heard.

The petitioners contended this violated principles of natural justice and statutory requirements.

Whether the Additional Collector is mandatorily required to afford an opportunity of hearing to the affected party prior to granting sanction for review under Section 51 of the M.P. Land Revenue Code, 1959.

Section 51 of the M.P. Land Revenue Code, 1959, which governs the power of revenue officers to review their orders.

Siddharth Dev Singh v. State of M.P. and Others, 2019 (1) MPLJ 175, which establishes that authorities are required to issue notice and provide an opportunity of hearing to the concerned person at the stage of obtaining sanction for exercising the power of review.

The court observed that the Additional Collector granted sanction for review of an order that had been passed in favor of the petitioners.

Applying the principles laid down in Siddharth Dev Singh, the court reasoned that any person whose interests are affected by the review of an order must be heard before the sanction for such review is granted.

The court noted that the respondents did not dispute the fact that no notice or opportunity of hearing was provided to the petitioners prior to the passing of the impugned order.

Consequently, the court found the Additional Collector's order to be in gross violation of the principles of natural justice and the procedural requirements of Section 51 of the Code.

The High Court quashed the order dated 02.03.2026 passed by the Additional Collector; however, the court granted liberty to the Additional Collector to proceed afresh in the matter in accordance with the law.

The petition was allowed.