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2026 Supreme(All) 33

HIGH COURT OF JUDICATURE AT ALLAHABAD
PRAKASH PADIA, J.
Satish And Others – Petitioners
Versus
Addl. Commissioner Meerut Division Meerut And Others - Respondents
Writ C. No. 56747 of 2016 
Decided On : 20-02-2026

Advocates Appeared:
For the Petitioners: Manish Dev Singh, Nipun Singh
For the Respondents: A.B. Singhal, Aditya Bhushan Singhal, Akhilesh Kumar Ojha, C.S.C., Mahesh Narain Singh, Santosh Kumar Upadhyay, Sharad Kumar Srivastava, Vinod Kumar Upadhyay.

A complaint under Section 198(4) of the U.P. Act can only be initiated by a 'person aggrieved' who has suffered a legal injury, emphasizing that mere residency does not confer such status.

Headnote:(A) U.P. Zamindari Abolition and Land Reforms Act, 1950 - Section 198(4) - Agricultural land allotment - Petitioners challenged the cancellation of their agricultural leases by authority, claiming erroneous jurisdiction and violation of principles of natural justice. Court held that the private respondents were not 'persons aggrieved,' thus, their complaint was not justifiable. (Paras 4, 10-12, 18-22, 28-32)

(B) Writ Jurisdiction - Scope - Writ petitions under Article 226 are maintainable only if the petitioner has a legal right adversely affected by the impugned action. (Paras 21, 26).

Facts of the case:
Petitioners were granted agricultural leases in 1994. Cancelation was based on a complaint by private respondents who claimed violations in the allotment process, yet lacked standing as 'aggrieved persons.'

Findings of Court:
The authority failed to establish that private respondents were affected legally by the allotment, leading to wrongful cancellation.

Issues: The main questions include the definition of 'person aggrieved' and whether the cancellation of allotments was justified.

Ratio Decidendi: The court reiterated that only legally aggrieved individuals can initiate cancellation proceedings, emphasizing the necessity for an established legal injury.

Result: Petition allowed, cancellations quashed.

Judgement Key Points

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Table of Content
1. arguments regarding petitioners' claims and legal errors. (Para 1 , 12 , 13)
2. background on the agricultural lease disputes. (Para 3 , 4 , 5 , 10)
3. observations on authority's procedures under section 198. (Para 8 , 18 , 19)
4. definition and interpretation of 'aggrieved person.' (Para 21 , 23 , 30)
5. judgment allowing the writ petition and setting aside lower orders. (Para 33 , 34)

JUDGMENT :

PRAKASH PADIA, J.

1. Heard Shri Nipun Singh, learned Senior Counsel assisted by Shri Abhijit Mishra, learned counsel for the petitioners, learned Standing Counsel appearing on behalf of Respondent Nos.1 & 2 and Shri Sunil Kumar Singh, learned counsel appearing on behalf of Respondent No.3/Land Management Committee and Shri Vinod Kumar Upadhyay, learned counsel appearing on behalf of private-respondents.

2. Pleadings have already been exchanged between the parties, hence with the consent of the counsel for the parties, the present writ petition is decided at the admission stage itself.

3. The present writ petition has been filed by the petitioners inter-alia with the following prayers-

"i. Issue an order, direction, or writ in the nature of the certiorari quashing the impugned judgment and order dated 03-10-2016 passed by the respondent no. 1 herein ie Additional Commissioner, Meerut Division, Meerut in revision no. 125/2015-15 Satish and others Vs. Jaipal and others, and revision no 126/2015-15 Harbhajan and others Vs. Ramgopal and others, and revision no. 117/2015-15 Ikram and others Vs Ravindra and others and in Revision no 116/2015-15 Kanwal Singh and others Vs. Raghuraj and others u/s 198(4) of U.P.Z.A. and L.R. Act (Annexure no.10 to the writ petition) and judgment and order dated 30-06-2016 passed by the respondent no. 2 herein i.e. Additional Collector/ADM (Administration), Bulandshahar in case no 17/2013 Brahm Singh and others Vs. Kanwal Singh and others, and in case no. 21/2013 Ravindra Singh and others Vs. Harbhajan Singh and others U/s 198(4) of U.P.ZA. and L.R. Act 1950 (Annexure No.7 to the writ petition) whereby and whereunder the agricultural leases as executed in favour of petitioners herein has been determined/cancelled u/s 198(4) of U.P.Z.A. and L.R. Act on wholly erroneous exercise of jurisdiction.

ii. Issue an appropriate order or direction against the res. no. 1 and 2 herein not to dispossess the petitioners herein concerning the leased land in pursuance of judgment and order dated 03-10-2016 passed by the respondent no 1 herein ie. Additional Commissioner, Meerut Division, Meerut in revision no. 125/2015-15 Satish and others Vs. Jaipal and others, and revision no. 126/2015-15 Harbhajan and others Vs. Ramgopal and others, and revision no. 117/2015-15 Ikram and others Vs. Ravindra and others and Revision no. 116/2015-15 Kanwal Singh and others Vs. Raghuraj and others u/s 198(4) of U.P.ZA. and L.R. Act (Annexure no.10 to the writ petition) and judgment and order dated 30- 06-2016 passed by the respondent no. 2 herein i.e. Additional Collector/ADM (Administration), Bulandshahar in case no. 17/2013 Brahm Singh and others Vs. Kanwal Singh and others, and in case no. 21/2013 Ravindra Singh and others Vs. Harbhajan Singh and others U/s 198(4) of U.P.Z.A. and L.R. Act 1950 (Annexure No.7 to the writ petition)."

4. Facts in brief as contained in the writ petition are that the Land Management Committee of the Gaon Sabha namely Biraudi Tajpur Tehsil Sikandarabad, District Bulandshahar passed a unanimous resolution on 20-04-1994, whereby an agricultural lease was granted in favour of various persons including the present petitioners. The aforesaid resolution was duly approved by the then Deputy Collector/Sub Divisional Officer vide order dated 12-5-1994. The private respondents namely Respondents Nos. 4 to 33 moved an application dated 29-06-1994 under sub section (4) of Section 198 of Uttar Pradesh Zamindari Abolition and Land Reforms Act, 1950 (hereinafter to be referred as "Act 1950"), before the Collector, Buland

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