Writ courts ordinarily will not reappraise disputed land demarcation absent jurisdictional error or perversity.

The petitioners challenged revenue orders concerning Survey Nos. 1182 and 1183 at Village Unav, District Datia, including the Collector’s revisional order dated 24 July 2025 and an earlier Naib Tehsildar order dated 23 September 2014.

They argued that the demarcation underlying subsequent encroachment proceedings conflicted with the 2014 demarcation and did not properly identify Government land. The Collector had directed proper demarcation before further action.

A spot demarcation was conducted on 30 July 2025, relying on a certified hand-traced map because the original Patwari map was unavailable; the report recorded the status of the relevant parcels and physical constructions.

The petitioners also challenged the consequential order dated 18 September 2025.

Whether the subsequent demarcation and consequential proceedings were unlawful because they allegedly conflicted with the earlier demarcation and did not comply with the Collector’s direction.

Whether the disputed questions concerning the identity, boundaries, and possession of the land warranted interference under Article 226 of the Constitution.

Article 226 jurisdiction is supervisory; the High Court ordinarily does not independently reappreciate disputed factual questions concerning land measurements, boundaries, revenue maps, or physical possession.

Interference is warranted where the decision-making process involves jurisdictional error, manifest arbitrariness, violation of natural justice, or patent perversity.

Proceedings concerning removal of encroachment or restoration of possession must comply with the applicable provisions of the Madhya Pradesh Land Revenue Code and the principles of natural justice.

The judgment cites no precedent.

The Court found that the Collector required proper demarcation before consequential action and that a spot exercise had in fact been conducted using the available map and revenue material.

The absence of the original Patwari map did not, by itself, invalidate the exercise, and the report recorded measurements, land status, and constructions observed at the site.

Disagreement with the report or inconsistency with an earlier demarcation raised factual questions for the competent revenue authority, not grounds for the High Court to undertake fresh fact-finding under Article 226.

The Court also found that the consequential action followed the demarcation and was not shown to breach the Collector’s direction.

It clarified that any proceedings for removal of encroachment or restoration of possession must comply with the Madhya Pradesh Land Revenue Code and natural justice, and that the petitioners may place their relevant documents before the competent authority, which must consider them before passing any final order affecting their possession or rights.