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2026 Supreme(Ori) 194

IN THE HIGH COURT OF ORISSA AT CUTTACK
A.C.BEHERA, J.
Chitaranjan Dash @ Chittaranjan Dash - Petitioner
Versus
Debadutta Pradhan, OAS, Tahasildar-Cuttack Sadar - Opposite Party
CONTC No.4513 of 2025
Decided On : 19-03-2026

Advocates:
Advocate Appeared:
For the Petitioner:M. Mohanty, Advocate.
For the Opposite Party : Mr. G. Mohanty, Standing Counsel

Timely compliance with statutory obligations by administrative authorities is essential for upholding the effectiveness of judicial directions.

Headnote:(A) Orissa Land Reforms Act, 1960 - Section 8-A - Non-compliance of court order - The Tahasildar was directed to dispose of the Conversion Misc. Case No.11 of 2020 within two months. However, submissions revealed that necessary approvals were not obtained from the State Pollution Control Board and Municipal Corporation within the stipulated time. (Paras 2, 4)

(B) Powers of High Court - The High Court has the authority to direct state authorities to comply with statutory obligations in a timely manner. The court highlighted the importance of timely action in administrative compliance. (Para 3)

Facts of the case:
The petitioner filed a CONTC for the non-compliance of an order regarding land conversion issued by the Tahasildar on 17.06.2025. The Tahasildar had still not received requisite approvals from other administrative bodies needed for compliance as of 16.03.2026.

Findings of Court:
The court directed the State Pollution Control Board and Cuttack Municipal Corporation to respond to the Tahasildar’s letters within 15 days, underscoring the need for quick compliance to the prior order.

Issues: The main issues involved the delay in obtaining necessary permissions by the Tahasildar to process the conversion case as directed by the earlier High Court order.

Ratio Decidendi: The court reiterated that administrative bodies must comply with court directions and statutory obligations promptly, ensuring governance effectiveness.

Result: CONTC disposed of with directions for compliance.

Table of Content
1. court's jurisdiction regarding compliance orders. (Para 1 , 2)
2. requirement for procedural compliance by authorities. (Para 3)
3. directions for compliance within stipulated time. (Para 4)
4. final order and disposal of the case. (Para 5 , 6 , 7)

Judgment :

A.C. Behera, J.

This CONTC has been filed by the petitioner for non-compliance of the order dated 17.06.2025 passed in W.P.(C) No.10410 of 2025 by the Tahasildar, Cuttack Sadar (O.P. No.4).

2. As per the final order dated 17.06.2025, the Tahasildar, Cuttack Sadar (O.P. No.4) was directed to dispose of the Conversion Misc. Case No.11 of 2020 under Section 8-A of the OLR Act, 1960 relating to the conversion of the land of the petitioner from Jalasaya to Gharabari within a period of two months from the date of such order i.e. from 17.06.2025.

3. Learned SC for the State submitted after obtaining instruction from the Tahasildar, Cuttack Sadar (O.P. No.4) that, in order to comply the directions given by this Court on dated 17.06.2025 in W.P.(C) No.10410 of 2025, the Tahasildar, Cuttack Sadar (O.P. No.4) has issued letters on dated 16.03.2026 to the State Pollution Control Board, Odisha as well as Cuttack Municipal Corporation for its approval in order to transmit the proceeding to the High Power Committee constituted as per the Division Bench decision of this Court, but till yet neither the State Pollution Control Board, Odisha nor Cuttack Municipal Corporation has complied to the said letters of the Tahasildar, Cuttack Sadar (O.P. No.4).

4. Taking the aforesaid submission of the learned SC for the State into account, it is felt proper for the final disposal of this CONTC directing the State Pollution Control Board, Odisha as well as Cuttack Municipal Corporation to comply the requirements made in the Letters dated 16.03.2026 of the Tahasildar, Cuttack Sadar (O.P. No.4) in respect of the Conversion Misc. Case No.11 of 2020 under Section 8-A of the OLR Act, 1960 within a period of 15 days from the date of receiving of this judgment.

The Tahasildar, Cuttack Sadar (O.P. No.4) is to take steps issuing reminders to the State Pollution Control Board, Odisha as well as Cuttack Municipal Corporation for the compliance of the requirements of his letters dated 16.03.2026 in order to dispose of Conversion Misc. Case No.11 of 2020 under Section 8-A of the OLR Act, 1960 on the basis of the order passed in WP(C) No.10410 of 2025.

5. Copy of this judgment be communicated to the State Pollution Control Board, Odisha, Cuttack Municipal Corporation and the Tahasildar, Cuttack Sadar (O.P. No.4) by the Registry immediately.

6. Free copies of this Judgment be supplied to the petitioner and learned SC for the State.

7. On the basis of the aforesaid directions and clarifications, this CONTC is disposed of.

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