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2026 Supreme(Raj) 319

HIGH COURT OF JUDICATURE FOR RAJASTHAN, BENCH AT JAIPUR
SANJEEV PRAKASH SHARMA, ACJ., SANJEET PUROHIT, J.
Sanyam Lodha, S/o. Late Shri Prakash Raj Lodha - Applicant
Versus 
State Of Rajasthan, Through Chief Secretariat, Government Of Rajasthan – Respondent
D.B. Writ Miscellaneous Application No. 182 of 2026, D.B. Writ Miscellaneous Application No. 170 of 2026, D.B. Writ Miscellaneous Application No. 171 of 2026
Decided On : 22-05-2026

Advocates Appeared:
For the Applicant : Mr. Rajendra Prasad, AG and Sr. Adv. with Mr. Sheetanshu Sharma and Mr. Anirudh Singh, Mr. Amit Kuri with Mr. Dharma Ram.
For the Respondent: Mr. Punit Singhvi, Mr. Prem Chand Dewanda with Mr. Abhishek Singh Dewanda and Mr. Shaurya Kaviya.

The constitutional requirement to conduct local body elections before the expiry of their term is mandatory; administrative delays caused by ongoing delimitation, lack of empirical reservation data, or seasonal conditions do not justify indefinite extensions of the election timeline.

Headnote:(A) Constitution of India - Articles 243-D, 243-E(3), 243-T, 243-U(3) - Representation of the People - Local Government Elections - Obligation to conduct elections prior to tenure expiry is a constitutional mandate, not a discretionary administrative task.

(B) Election Schedule - Extension of time - Delay owing to delimitation of wards or ongoing empirical studies regarding reservation quotas does not constitute a valid legal ground to bypass constitutional timelines.

(C) Reservation Policy - Triple Test - Adherence to Supreme Court guidelines on empirical inquiry for backward class representation - Lack of commission report cannot be used to permanently stall the democratic process where elections are overdue.

(D) Judicial Discretion - Environmental or climatic factors - Seasonal weather conditions are insufficient to override the mandatory duty of holding timely elections. (Paras 7.1, 7.2, 7.3)

Facts of the case:
The State authorities filed applications seeking an extension of time for conducting elections to rural and urban local government bodies, citing ongoing delimitation of wards, pending receipt of reports from a dedicated commission concerning backward class reservations, and prevailing seasonal weather conditions as impediments.

Findings of Court:
The court held that while limited extensions for delimitation were previously granted, further delays to accommodate administrative studies or seasonal weather were untenable. The court noted that administrative roadblocks should not be used as an excuse to avoid constitutional mandates. Following established precedents, the court directed that election processes must be completed within a fixed timeframe.

Issues: The primary issue was whether the constitutional obligation to conduct timely local body elections could be lawfully deferred due to incomplete administrative processes, pending backward class reservation studies, and seasonal weather constraints.

Ratio Decidendi: The court maintained that the constitutional requirement for holding elections for local bodies is mandatory and must not be subordinated to administrative delays or lack of empirical data. Election cycles must be preserved, and in the absence of finalized reservation data, the polls should proceed as per the legal framework without further deferment on flimsy grounds.

Result: Applications allowed in part; directions issued for completion of all preparatory work by 20.06.2026 and final conduct of elections by 31.07.2026.

Table of Content
1. overview of multiple applications seeking extension to complete local body election functions. (Para 1 , 2)
2. state claims regarding delimitation complexities and pending obc commission empirical findings as justification for delay. (Para 3)
3. election commission asserts readiness while acknowledging statutory bottlenecks caused by the state government. (Para 4)
4. petitioners argue that statutory election timelines are mandatory and cannot be sacrificed for procedural convenience. (Para 5)
5. court rejects extraneous delay excuses and mandates election completion by a fixed deadline notwithstanding pending reports. (Para 6 , 7 , 8)

Order :

Sanjeet Purohit, J.

1. D.B. Misc. Application No. 182/2026 by the State Election Commission, Rajasthan; D.B. Misc. Application No. 170/2026 by the Panchayati Raj Department, Government of Rajasthan; and D.B. Misc. Application No. 171/2026 by Local Self Government Department, Government of Rajasthan, have been filed with common prayer, seeking extension of suitable time for holding and completing the elections of Rural and Urban Local Bodies in the State of Rajasthan.

2. In essence, it is contended that in spite of making all possible efforts, owing to unavoidable circumstances, due compliance of directions contained in para 224.7 of the judgment dated 14.11.2025 passed by this Court in a batch of writ petitions led by D.B. Civil Writ Petition No. 7718/2025, Sheela Kumari vs. State of Rajasthan & Ors. for conducting and completing the elections of the Rural Local Bodies (RLBs) as well as the Urban Local Bodies (ULBs) within the prescribed time period, could not made and thus, respective respondent Departments and the State Election Commission, Rajasthan have prayed for extension of the time period.

3. Arguing on behalf of State of Rajasthan, learned Advocate General - Mr. Rajendra Prasad, contended that while deciding a batch of writ petitions challenging delimitation exercise undertaken by the State of Rajasthan in relation to various Gram Panchayats as well as Municipal Bodies, along with writ petitions seeking directions for conduct of elections of RLBs and ULBs, this Court, vide judgment dated 14.11.2025, directed the State authorities to complete the exercise of delimitation on or before 31.12.2025 and thereafter to conduct and complete elections of all local self-government bodies, i.e. Panchayats as well as Municipalities, simultaneously, on or before 15.04.2026.

Extension of the time limit as prescribed in para 224.7 of the judgment dated 14.11.2025 has been sought while narrating various subsequent facts, explained in applications i.e. Writ Misc. Application Nos. 170/2026 and 171/2026, which are briefly stated as under :

3.1 It is contended that, in pursuance of directions issued by this Court vide judgment dated 14.11.2025, delimitation notifications in relation to various Panchayats were issued on 19.11.2025, 20.11.2025 and 21.11.2025. Pursuant to said notifications, several representations/objections were received and after considering and deciding the same, the entire exercise of delimitation of the Panchayati Raj Institutions was completed by issuance of final notifications dated 28.12.2025 and 31.12.2025.

3.2 After completion of said process of delimitation, directions were issued on 25.01.2026 for publication of wards. Simultaneously, the State Election Commission issued orders on 31.12.2025 for preparation of the voter lists of the Panchayati Raj Institutions and the final voter lists were published on 25.02.2026. 3.3 Learned Advocate General however contended that the process of delimitation of the ULBs was affected due to adjudication made in Part – C and directions contained in para224.3 of the judgment dated 14.11.2025.

3.4 It is stated that out of total 309 ULBs, delimitation of internal wards was done / changed in relation to 113 ULBs, out of which delimitation notifications in respect of 03 ULBs were challenged and delimitation notifications pertaining to said

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