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2025 Supreme(SC) 2098

SANJAY KUMAR, ALOK ARADHE
Bhika Ram – Appellant
Versus
State Of Rajasthan – Respondent


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

Table of Content
1. facts about the creation of revenue villages. (Para 2 , 3 , 4 , 5 , 6 , 7 , 8)
2. high court decisions regarding appeals. (Para 9 , 10)
3. arguments presented by both sides. (Para 11 , 12 , 13)
4. court's analysis of statutory provisions. (Para 14 , 15 , 16 , 17)
5. conclusion and restoration of the single judge's order. (Para 18 , 19)

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, n

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    Judicial Analysis

    None of the cases listed explicitly indicate that they have been overruled, reversed, or otherwise treated as bad law. There are no keywords such as "overruled," "reversed," "disapproved," or similar language that suggest a negative treatment or invalidation of these decisions. Therefore, based solely on the provided information, no case is identified as bad law.

    Followed/Positive Treatment:

    Joga Ram S/o. Shri Dala Ram vs State of Rajasthan, Through Its Special Secretary, Revenue Department (Group-1), Government of Rajasthan - 2025 0 Supreme(Raj) 1436: The case discusses the court’s stance on circulars allowing arbitrary naming of revenue villages, emphasizing that such circulars violate guidelines and undermine communal harmony. The language suggests this is a settled legal position, but there is no indication that subsequent cases have challenged or overruled this ruling, so it appears to be a positive or affirmed decision.

    State Of Punjab VS Ram Lubhaya Bagga - 1998 2 Supreme 231: The case affirms that the Punjab Government’s Medical Reimbursement Policy, restricted by financial constraints, does not violate Article 21 of the Constitution. The language indicates a clear legal conclusion, but again, no subsequent treatment is provided to suggest it has been overruled or questioned.

    Distinguished/Clarified Treatment:

    No cases in the list explicitly state that they have been distinguished or clarified by subsequent rulings.

    Criticized/Questioned:

    No indications are present that either case has been criticized or questioned in subsequent decisions.

    Both cases are presented with straightforward summaries that do not mention subsequent treatment or judicial history, making their current status unclear. Without additional case law references or treatment history, it is difficult to determine whether these decisions have been upheld, distinguished, or criticized later. Therefore, their treatment remains uncertain based on the provided data.

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