$~87 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(C) 1911/2026 & CM APPLs. 9278/2026, 9279/2026 RAMESH PAL MEHTA .....Petitioner Through: Mr. Sunil Chauhan and Mr. Vatsala Chauhan, Advocates.

versus FINANCIAL COMMISSIONER & ORS. .....Respondents Through: Mr. Raghvendra Upadhyay, Panel Counsel (GNCTD) with Mr. Ankit Jaiswal and Ms. Purnima Jain, Advocates for R-1 & 2.

CORAM:

HON'BLE MR. JUSTICE SANJEEV NARULA

O R D E R

% 10.02.2026

1. The Petitioner was arrayed as Respondent No. 2 before the Financial Commissioner in a revision petition under Section 42 of the East Punjab Holdings (Prevention of Fragmentation) Act, 1948 filed by Prashant Mudgal and Virender Rana. The said petition assailed orders dated 26^th September, 2022 and 23^rd February, 2024 passed by the Consolidation Officer/Tehsildar, Alipur, Delhi. In those proceedings, the Petitioner questioned the locus standi of the revision petitioners in those proceedings.

2. The revision petition was disposed of by the impugned order dated

24^th September, 2025, holding as under:

“13. The above rulings do not provide for continued applicability of the Delhi Land Reforms Act, 1954 by the revenue courts. After the declaration of the land/village i.e. Bakoli as Low Density Residential Area vide notification dated 18.06.2013, the definition of the land which is derived from the Delhi Land Reforms Act is non-est once the Land Reforms Act goes In terms of the above judgment.

14. Averting to the East Punjab Holdings (Consolidation and Prevention of Fragmentation) Act, 1948, the purpose of this Consolidation Act as mentioned in Its preamble is "An Act to provide for the compulsory consolidation of agricultural holdings and for preventing the fragmentation of agricultural holdings in the State of Punjab and for the assignment or reservation of land for common purpose of the village . The entire outcome of the process of consolidation to achieve the purpose staled in the preamble of consolidation is to prepare a new record of rights in accordance with the Land Revenue Act as per Section 22 of the Consolidation Act.

15. The basic purpose of the Consolidation Act therefore is to prevent fragmentation of land and to render agricultural activity to remain viable. The mother document on which the entire consolidation is based on, is the 'record of rights'. The record of rights in the Consolidation Act is as defined in Sections 6 and 22 of the East Punjab Holdings (Consolidation and Prevention of Fragmentation) Act, 1948 and takes Its definition from the Punjab Land Revenue Act. In the case of GNCTD, the same Punjab Land Revenue Act, 1887 has been extended to Delhi through the aegis of Delhi Land Revenue Act, 1954.

16. As already explained in the foregoing, once the Delhi Land Reforms Act and the Delhi Land Revenue Act cease to exist, post notification under Section 11 of Delhi Development Act, 1957 the consolidation proceedings, even if started before or after the said notification cannot continue. This is because 'record of rights' of land as legally defined and sanctified by the-Delhi Land Reforms Act and the Delhi Land Revenue Act cannot continue after the notification and the said Revenue acts ceasing to exist except for reference and record purposes. Therefore, once the applicability of Delhi Land Reforms Act, 1954 ceases as per the judgment of the Hon'ble High Court in WP(C) No.3502/2022 titled Rajeev Shah (Deceased) through LR Gayatri Shah Vs. Government of NCT of Delhi & Ors., the revenue laws and as a logical extension as explained elsewhere above, the consolidation law cannot continue to remain valid. The remedies will lie elsewhere.

17. In the light of all the foregoing, to review the matter where the village already stood declared as Low Density Residential Area In 2013 would involve entering into an area where the revenue courts have no jurisdiction to enter. Therefore, in terms of the above judgments of the Hon'ble High Court the revenue courts cease to have jurisdiction qua the lands cov