1. Creation of new revenue villages under Section 16, Rajasthan Land Revenue Act, 1956 — Challenge to notification based on village names derived from individuals. (Para 4 , 5 , 6 , 7 , 8 )
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2025 Supreme(SC) 2098
SUPREME COURT OF INDIA
Sanjay Kumar, Alok Aradhe, JJ.
Bhika Ram & Anr. - Appellants
Versus
State Of Rajasthan & Ors. - Respondents
Civil Appeal No. 15093 of 2025 (@ SLP (C) No. 27965 of 2025)
Decided On : 19-12-2025
Important Points
The creation of Revenue Villages must adhere to naming policies to maintain communal harmony, and notifications violating these policies lack legal sanctity.
Subject
Administrative Law - Land Revenue
Act Referred
Headnote
(A) Rajasthan Land Revenue Act, 1956 - Section 16 - Creation of new Revenue Villages - The Division Bench erred in allowing the appeal as the names of the Revenue Villages were based on individuals, violating the circular dated 20.08.2009, mandating naming conventions to foster communal harmony - The impugned notification was quashed for contravening established policy. (Paras 14, 15, 17)
(B) Jurisdictional Issues - The appellants were found to have locus standi in challenging the notification, and retrospective reopening of settled matters was not warranted. (Paras 13, 17)
Facts of the case:
The appellants contested the notification creating Revenue Villages 'Amargarh' and 'Sagatsar', arguing that their names derived from individuals violated statutory naming norms. The learned Single Judge upheld their objection, which was reversed by the Division Bench.
Findings of Court:
The creation of named villages violated the State's policy to avoid individual-based names, thus the notification was invalid.
Issues: Whether the names of the Revenue Villages violated the naming criteria under the circular, and whether the appellants had the standing to appeal.
Ratio Decidendi: The court emphasized adherence to the State's policy on village naming to uphold communal harmony, restoring the Single Judge's order quashing the notification.
Result: Appeal allowed.
(B) Jurisdictional Issues - The appellants were found to have locus standi in challenging the notification, and retrospective reopening of settled matters was not warranted. (Paras 13, 17)
Facts of the case:
The appellants contested the notification creating Revenue Villages 'Amargarh' and 'Sagatsar', arguing that their names derived from individuals violated statutory naming norms. The learned Single Judge upheld their objection, which was reversed by the Division Bench.
Findings of Court:
The creation of named villages violated the State's policy to avoid individual-based names, thus the notification was invalid.
Issues: Whether the names of the Revenue Villages violated the naming criteria under the circular, and whether the appellants had the standing to appeal.
Ratio Decidendi: The court emphasized adherence to the State's policy on village naming to uphold communal harmony, restoring the Single Judge's order quashing the notification.
Result: Appeal allowed.
Legal Category Hierarchy
Advocates appeared:
For the Petitioner(s): Mr. Manish K. Bishnoi, AOR Mr. Dr.manish Singhvi, Sr. Adv. Mr. Karan Bishnoi, Adv.
For the Respondent(s): *Mr. Vivek Firoda, Adv. Mr. Hanuman Ram Mundan, Adv. Mr. Sharwan Kumar Godara, Adv. Mr. Shubham Jain, AOR Ms. Aneesha Rastogi, Adv. Mr. S. Udaya Kumar Sagar, AOR
For the Petitioner(s): Mr. Manish K. Bishnoi, AOR Mr. Dr.manish Singhvi, Sr. Adv. Mr. Karan Bishnoi, Adv.
For the Respondent(s): *Mr. Vivek Firoda, Adv. Mr. Hanuman Ram Mundan, Adv. Mr. Sharwan Kumar Godara, Adv. Mr. Shubham Jain, AOR Ms. Aneesha Rastogi, Adv. Mr. S. Udaya Kumar Sagar, AOR
Table of Contents
2. Violation of government circular prohibiting village names based on individuals — Contention that circular is merely directory and statutory procedure was followed. (Para 11 , 12 , 13 )
3. Government policy decisions are binding on the state unless lawfully amended; naming villages after individuals contravenes established policy and violates Article 14. (Para 16 , 17 )
4. A policy decision, though executive in nature, binds the government; any action in derogation thereof without valid justification is arbitrary and violative of Article 14. (Para 16 )
5. Appeal allowed — Division Bench judgment quashed — Single Judge order restoring the challenge to the notification restored. (Para 18 , 19 )
6. Does a government circular or policy decision bind the government?
Yes, a policy decision, although executive in nature, binds the government. The government cannot act contrary to its own policy unless that policy is lawfully amended or withdrawn. (Para 16 )
7. What is the legal consequence of a government action that contravenes its own policy without justification?
Any action taken in derogation of a government policy, without amendment or valid justification, is considered arbitrary and violative of Article 14 of the Constitution of India. (Para 16 )
8. Can a notification creating revenue villages be quashed if the names violate a government circular?
Yes, if a government circular mandates that village names shall not be based on individuals, and the notification violates this policy, the notification lacks legal sanctity and can be quashed. (Para 15 , 17 )
JUDGMENT :
ALOK ARADHE, J.
Leave granted.
2. This appeal challenges the judgment dated 05.08.2025 passed by a Division Bench of the High Court of Judicature for Rajasthan by which appeal preferred by respondent nos. 6 to 9 was allowed and order dated 11.07.2025 passed by the learned Single Judge has been set aside. For a proper appreciation of controversy, the relevant facts, in brief, may be noted.
3. The appellants and respondent Nos. 6 to 9, are residents of village Sohda, District Barmer in the State of Rajasthan.
4. Pursuant to a proposal submitted by the Gram Panchayat Sohda, for the creation of new Revenue Villages, the Tehsildar Gida (Land Records), District Barmer, issued certificates dated 24.12.2020 stating that he had personally and thoroughly verified all the relevant aspects, concerning formation of four new Revenue Villages, namely (i) Nainoni Darziyon Ki Dhani, (ii) Sagatsar, (iii) Amargarh and (iv) Hemnagar carved out of Meghwalon Ki Dhani, Revenue Village Sohda, Patwar Mandal Sohda, District Barmer. It was specified therein that the headquarters of Revenue Villages Sagatsar and Amargarh would be at Khasra Nos.118 and 73. The certificate further recorded that the proposed villages were not associated with any individual, religion, caste or community and there existed no dispute regarding their creation. On the same day, Tehsildar forwarded the proposal to the District Collector (Land Records), Barmer.
5. On 24.12.2020 and 29.12.2020, one Amarram and Badli Kunwar, wife of Sagat Singh, executed affidavits that they agree to donate the land for proposed Revenue Villages, namely Amargarh and Sagatsar.
6. The State Government, in exercise of the powers under Section 16 of the Rajasthan Land Revenue Act, 1956 (hereinafter, referred to as the ‘the Act’) issued a notification on 31.12.2020 and created several new Revenue Villages. In the said notification, Amargarh and Sagatsar from Meghwalo Ki Dhani, Revenue Village Sohda, Patwar Mandal Sohda, District Barmer, were notified as separate Revenue Villages. Consequent thereto, the District Collector on 14.01.2021 issued an order specifying the area and population of the newly constituted Revenue Villages.
7. On 10.01.2025, the Rural Development and Panchayati Raj Department, Government of Rajasthan, issued directions for reorganization, re-demarcation and creation of the new Gram Panchayats and Panchayat Samitis, authorising the District Collectors to act under Sections 9 , 10 and 101 of Rajasthan Panchayati Raj Act, 1994. In furtherance thereof, a public notice dated 07.04.2025, was issued inviting objections. An objection dated 21.04.2025 was submitted by villagers of Meghwalo ki Dhani, asserting that the names of new Revenue Villages, namely ‘Amargarh’ and ‘Sagatsar’ were derived from the names of individuals.
8. The appellants approached the High Court by filing a Writ Petition challenging the validity of the notification dated 31.12.2020, insofar as it related to the creation of Revenue Villages, namely Amargarh and Sagatsar.
9. The learned Single Judge by an order dated 11.07.2025, held that the names of Revenue Villages were derived from the names of individuals, namely Amarram and Sagat Singh, who had also agreed to donate the land. The learned Single Judge by placing reliance on two Single Bench decisions of the High Court in Moola Ram v. State of Rajasthan (S.B. Civil Writ Petition No.3470/2025) decided on 18.02.2025 and Joga Ram & Anr. v. State of Rajasthan & Ors., (S.B. Civil Writ Petition No.7275/2025) decided on 08.05.2025 quashed the notification dated 31.12.2020 qua the Revenue Villages, namely Amargarh and Sagatsar. The learned Single Judge granted the liberty to rename the Revenue Villages in accordance with law.
10. Being aggrieved, respondent nos. 6 to 9, though not parties to the Writ Petition, preferred an appeal along with an application for leave to appeal. The Division Bench by the impugned order dated 05.08.2025, inter alia held that the benefit of deci
