Section 264 bars Section 32 proceedings concerning land held from the Central Government.

The petitioner challenged the Additional Collector’s order dated 31 August 2026, which vacated an interim protection order made on 3 August 2026 in proceedings initiated by the petitioner under Section 32 of the Madhya Pradesh Land Revenue Code, 1959.

The petitioner alleged irregularities in the recording of title and payment of compensation concerning government land and sought, among other reliefs, mutation of the land in the State’s name and action against those allegedly involved.

The land had been acquired by the Central Government for Northern Coalfields Limited (NCL), and the petitioner’s application itself referred to that acquisition.

Whether the petitioner’s application under Section 32 of the Madhya Pradesh Land Revenue Code, 1959, was maintainable in light of Section 264 of that Code, where the land had been acquired by the Central Government and transferred to NCL.

Whether the proceedings under Section 32, including the interim order and the order vacating it, could stand if the application was not maintainable.

Section 264 of the Madhya Pradesh Land Revenue Code, 1959, provides that the Code does not apply to a person who holds land from the Central Government.

The Court held that where rights over land vest in the Central Government following acquisition and the land is thereafter transferred to a company, the Code ceases to apply by virtue of Section 264; accordingly, an application under Section 32 cannot be entertained in respect of such land.

The Court relied on the acquisition notification and the petitioner’s own application, which acknowledged that the land had been acquired for NCL by the Central Government.

Applying Section 264, it concluded that the Land Revenue Code—including Section 32—did not apply to the matter.

The Additional Collector had therefore acted without authority in taking cognizance of the application and making orders under that provision; the proceedings were consequently a nullity.

It also dismissed the petitioner’s application under Section 32 and disposed of the writ petition.