Serious disputes regarding right, title, and interest in land cannot be adjudicated under Article 226.

The petitioners filed a writ petition seeking a Mandamus to direct the State of Jharkhand to vacate 51 acres of land situated in Mouza-Mangrodih, Giridih (Khata No. 96, Plot No. 2717).

They claimed the land was ancestral Raiyati property registered in the name of Polo Marik

They alleged the State had forcefully dispossessed them to construct a cold storage without prior notice or compensation

The Respondent-State countered that the land was recorded as Gairmazurua Khas Parti Kadim in the cadastral survey (1908–1911) and that the petitioners’ ancestors held leases that expired by 1912.

The State further disputed the validity of Register-II entries and noted discrepancies in the land boundaries

Whether a writ petition under Article 226 of the Constitution of India is the appropriate remedy to adjudicate a "serious dispute" regarding the right, title, and interest of land

The court applied the established principle that Article 226 of the Constitution of India is a summary jurisdiction and is not intended for the adjudication of complex, contested questions of title or recovery of possession

The court affirmed that such disputes are strictly within the purview of the competent Civil Court through a regular civil suit

The Court observed that the case presented a "serious dispute" involving contradictory claims of ownership: the petitioners relied on ancestral Raiyati claims, while the State relied on historical cadastral survey records and the expiration of colonial-era leases

Justice Ananda Sen reasoned that the High Court cannot decide on the validity of Register-II entries or determine the legal title of a property when the facts are heavily contested by the State

Since the petitioners sought recovery of possession and a declaration of title, the court found that the evidentiary requirements to resolve such a conflict could not be met in a writ proceeding

The petition was disposed of with the observation that the petitioners are at liberty to approach the appropriate Civil Court to file a suit for the establishment of right, title, and recovery of possession