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2026 Supreme(Online)(Chh) 10547

HIGH COURT OF CHHATTISGARH AT BILASPUR
Amitendra Kishore Prasad, J
BALUD RAM SAHU – Appellant
Versus
STATE OF CHHATTISGARH – Respondent
WPC No. 1827 of 2026



Advocates:
For the Appellants/Petitioners: J. K. Gupta
For the Respondents: Anadi Sharma

A writ petition is not maintainable for disputes involving factual questions of land demarcation and possession when an efficacious alternative statutory remedy is available under the Chhattisgarh Land Revenue Code, 1959.

Headnote:(A) Land Revenue - Demarcation and Possession - Alternative Remedy - Where a dispute pertains to the demarcation of land, correction of revenue records, and issues of possession involving disputed questions of fact, the appropriate remedy lies with the competent revenue authorities under the Chhattisgarh Land Revenue Code, 1959, and a writ petition is not maintainable. (Para 7, 8)

Issues: Whether a writ petition is maintainable for seeking land demarcation and correction of revenue records when an efficacious alternative statutory remedy exists under the Chhattisgarh Land Revenue Code, 1959.

Table of Content
1. petitioners seek judicial intervention for land demarcation and correction of records due to alleged administrative errors and possession disputes. (Para 1 , 2)
2. conflict between the claim of constitutional violation (art 14, 300-a) and the existence of a statutory alternative remedy under land revenue laws. (Para 3 , 4 , 5)
3. factual disputes regarding land boundaries must be adjudicated by competent revenue authorities rather than through writ jurisdiction. (Para 6 , 7 , 8 , 9)

(Cause Title is taken from CIS System)

Order on Board

1. The petitioners have filed this writ petition seeking following reliefs:

“10.1 That, petitioner most respectfully prays that this Hon'ble Court may kindly be pleased to direct the proper demarcation/batankan of Khasra Nos. 246/2 and 253/3, Village Jhumka, strictly in accordance with law.

10.2 Quash and set aside the illegal investigation report submitted by the Patwari and Revenue Inspector dated 18.09.2024, 27.06.2025 & 11.11.2025 being arbitrary and illegal.

10.3 Issue a direction/order to the to register a First Information Report (FIR) against the private respondents and involved officials, and to ensure a time-bound, fair, and impartial investigation into the illegal and forcible cutting and removal of crops from the Petitioner's land.

10.4 Direct the respondent no. 10 to 13 to remove the blunt in the agricultural land.

10.5 Any other relief or reliefs that may be deemed fit and proper in the facts and circumstances of the case may be also kindly be granted.”

2. Facts of the case, as projected, are that the petitioners have approached this Court stating that the lands bearing Khasra Nos. 246, 252, 253, and 258 were not demarcated since the year 1927, and the first demarcation exercise was carried out only in the year 2023. According to the petitioners, such delayed demarcation has led to serious discrepancies and disputes regarding boundaries and possession. It is the case of the petitioners that Petitioner No. 1 had purchased agricultural land bearing Khasra No. 246/2 admeasuring 0.186 hectare through a registered sale deed dated 04.01.2008 and has been in continuous possession and cultivation of the said land since then. It is further contended that the petitioner had taken possession of approximately one acre of land, which included portions of Khasra Nos. 246 and 253. However, due to an alleged clerical or record-related error at the time of registration, the land was reflected in fragmented form, leading to confusion regarding its actual boundaries. The petitioners further submit that several adjoining landholders have also purchased lands from the same vendors over a period of time through different sale deeds, which has further complicated the issue of identification and demarcation of the respective lands. Due to the alleged incorrect demarcation carried out by the revenue authorities, particularly the Patwari, disputes arose between the petitioners and private respondents. It is further stated that the petitioner had submitted a complaint dated 28.10.2023 before the concerned authorities regarding the erroneous demarcation; however, no effective action was taken. The situation further escalated when, according to the petitioners, private respondents attempted to harvest crops from the petitioner’s land, leading to lodging of an FIR by the petitioner. It is also alleged that thereafter a false counter FIR was lodged against the petitioner by the private respondents with an intention to pressurize the petitioner and deprive him of his lawful rights. The criminal proceedings arising therefrom have been stayed by this Court. The petitioners further contend that despite making several representations to the revenue authorities for correction of demarcation and proper identification of land, the authorities have failed to take any concrete action. It is also brought on record that an enquiry was conducted by the revenue authorities, wherein it was noted t

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