Judicial Analysis Court Copy Headnote Facts Arguments Court observation

2026 Supreme(Raj) 109

IN THE HIGH COURT OF JUDICATURE FOR RAJASTHAN BENCH AT JAIPUR
INDERJEET SINGH, RAVI CHIRANIA, JJ.
Sunil Jangid S/o Heeralal – Appellant
Versus
The State of Rajasthan – Respondent
D.B. Civil Writ Petition Nos. 97, 194, 197, 299, 320, 325, 352, 357, 371, 399, 412, 416, 428, 433, 434, 437, 440, 447, 448, 542, 586, 662, 702, 703, 724, 746, 768, 790, 792, 793, 794, 797, 813, 816, 819, 847, 853, 861, 878, 881, 884, 885, 895, 896, 901, 912, 915, 972, 981, 988, 989, 991, 1009, 1012, 1015, 1016, 1026, 1042, 1043, 1056, 1057, 1058, 1108, 1220, 1221, 1226, 1235, 1259, 1260, 1263, 1265, 1269, 1273, 1323, 1357 of 2026, D.B. Civil Writ Petition Nos. 18406, 18846, 18877, 18882, 19320, 19336, 19436, 19482, 19559, 19665, 19685, 20158, 20181, 20524, 20565, 20656, 20805 of 2025, D.B. Civil Writ Petition No. 13489 of 2024
Decided On : 21-01-2026

Advocates Appeared:
For the Appellants : R.N. Mathur, R.D. Meena, Suresh Pareek, S.L. Sharma, Rahul Kamwar, Vaibhav Nirmal, Bharat Kumar, Shubham Rohila, Raghunandan Sharma, Abhinav Shrivastava, Ayush Bishnoi, Prem Chand Dewanda, Abhisehk Singh, Ajay Poonia, Vikas Meena Ravi Palsaniya, Shailesh Prakash Sharma, A.R. Meena, Lakhan Singh Tomar, Hari Kishan Saini, Sudarshan Laddha, Laxmi Kant Malpura, Vaibhav Nirmal, Lakshya Sharma, Yogesh Kumar Sharma, Balveer Singh Beniwal, Aradhana Swami, Khurshid Ahmed Khan, Pradeep Kalwania, Jai Raj Tantia, Dharmendra Sharma, Ved Prakash Saini, Asgar Khan, Satyapal Poshwal, Pradeep Singh, Anil Kumer Beri, Komal Dua, Piyush Sharma, Hari Kishan Saini, Sanjay Mehrish, Ram Pratap Saini, Mayank Kumar Choudhary, Amit Singh Shekhawat, Prashant Kumar Sharma, Himanshu Jain, Dharmendra Sharma, Anupam Sharma, Sumer Singh Ola, Prashant Kumar Sharma, Ankur Rastogi, Azad Ahmed, Hanuman Choudhary, Sanjeev Kumar Mahala, Anurag Shukla, Gajendra Vyas, Ravi Kumar Palsaniya, Bharat Yadav, Vinod Kumar Sharma, Yashodhar Pandey, Vivek Joshi, Atar Singh, Abhimanyu Singh Yaduvanshi, Monika, Tanveer Ahamd, R.D. Meena, Sandeep Saxena, Aamir Khan
For the Respondents: Rajendra Prasad, Harhita Thakral, Dhriti Laddha, Tanmay Goyal, Kapil Prakash Mathur, Ashutosh, Prateek Saxena, Saurabh Sharma, Divya Rathore, Anshul, Anjali, Pranay, Sumit Purohit, Savita Nathawat

The court held that notifications for delimitation of Gram Panchayats are administrative acts not subject to judicial review unless proven arbitrary, and non-adherence to internal guidelines does not invalidate the process.

Headnote:(A) Rajasthan Panchayati Raj Act, 1994 - Sections 9, 10, 101, and 115 - Notifications issued for delimitation of Gram Panchayats challenged - Petitioners argued that notifications resulted in arbitrary relocation of villages, ignored administrative guidelines, and acted against the interests of certain villagers. (Paras 2, 4, 18)

(B) Judicial Review - Scope and maintainability - Final notifications of delimitation cannot be interfered with unless manifest arbitrariness is established. Guidelines not possessing statutory character cannot invalidate the notifications. (Paras 148, 165)

Facts of the case:
Petitioners contended that the delimitation process violated guidelines and marginalized certain villages without justifiable cause. (Paras 3-4)

Findings of Court:
The Court held that adequate process was followed in issuing notifications and denied orders for a detailed examination of objections. (Paras 6, 18)

Issues: The main issues included the adherence to guidelines for delimitation and the legal basis for challenging final notifications.

Ratio Decidendi: Court ruled that notifications on delimitation are administrative in nature and not subject to judicial review unless arbitrary; guidelines serve only as internal compliance mechanisms. (Paras 148, 224.1)

Result: Writ petitions dismissed.

Table of Content
1. challenge to delimitation notifications (Para 2 , 3)
2. arguments regarding arbitrariness of the notifications (Para 4 , 5 , 6 , 7 , 8 , 9)
3. legal standards in election and delimitation (Para 10 , 11 , 16 , 17)
4. court's views on prior judicial rulings (Para 12 , 18)
5. writ petitions dismissed (Para 19)

ORDER :

1. In the present batch of the petitions, since common questions are involved, therefore, at the request of counsel for the parties, these petitions have been heard together and are being decided by the present order.

2. These writ petitions have been filed by the petitioners challenging the notifications dated 20.11.2025 and 28.12.2025 issued by the respondents in relation to delimitation of various Gram Panchayats, Panchayat Samitis, and Zila Parishads; change of their headquarters; merger of one Gram Panchayat with another; inclusion or exclusion of villages from one Gram Panchayat to another.

3. The facts, as prayed, have been noticed from D.B. Civil Writ Petition No.988/2025. In the first round of litigation, several writ petitions (CWP-7781/2025-Sheela Kumari Vs. State of Raj. & Ors., & other petitions) were filed before this Court challenging the initiation of the process of delimitation of Gram Panchayats, Panchayat Samities and Zila Parishads by the State Government. The said writ petitions were decided by a Coordinate Bench of this Court vide order dated 14.11.2025 directing the respondents to conclude the process of delimitation by 31.12.2025 with a further direction to hold the elections of all the local bodies, including Panchayats and Municipalities, on or before 15.04.2026. The order dated 14.11.2025 passed by the Coordinate Bench of this Court was challenged by some of the writ petitioners before the Hon’ble Supreme Court by filing of Special Leave Petition No. 36874 of 2025 (Sanyam Lodha v. State of Rajasthan & Ors.), wherein the State Government gave an undertaking to conclude the elections by 15.04.2026 and the said SLP was dismissed by the Hon’ble Supreme Court vide order dated 19-12-2025. The aforesaid order 14.11.2025 passed by the Division Bench of this Court was also challenged by some of the writ petitioners before the Hon’ble Supreme Court by filing of Special Leave to Appeal No.34/2026 (Villagers of Revenue Village Singhaniya & Anr Vs. State of Rajasthan & Ors.) and the said SLP was also dismissed by the Hon’ble Supreme Court granting liberty to the aggrieved persons to approach the competent authority with regard to shifting of headquarters. Subsequently, in furtherance of the earlier notification issued under Sections 9, 10, & 101 of the Rajasthan Panchayati Raj Act, 1994 (hereinafter referred to as “the Act of 1994”), the respondents issued another notification dated 20.11.2025. After conclusion of the proceedings, a further notification dated 28.12.2025 was issued for correction of clerical mistakes as well as for considering the representations and making additional amendments in the earlier notification. Both these notifications dated 20.11.2025 & 28.12.2025, as stated above, have been challenged in the present batch of the petitions.

4. Learned counsels appearing on behalf of the petitioners argued that by issuance of the notifications impugned herein, the respondents have included their villages in other Gram Panchayats without any justifiable reason. They further argued that the headquarters of certain Gram Panchayats have been shifted arbitrarily from one village to another without any administrative exigency. They further argued that the respondents have failed to follow their own guidelines governing the inclusion or exclusion of villages from one Gram Panchayat to another or from one Panchayat Samiti to another. They further argued that some villages have been attached to the Gram Panchayats situated at a distance of more than 6 km, which is in violation of their own guidelines. They further argued that the respondents have issued the impugned notifications, ignoring