The court held that the principles of natural justice must be upheld in suo-motu revision proceedings, requiring the authority to furnish necessary documents and provide a fair opportunity for hearing before passing final orders.

ORDER (ORAL)

:

Heard M/s. M. Pratheek Reddy, learned counsel for the petitioners; Mr. L. Ravinder, learned Assistant Government Pleader for Revenue appearing on behalf of respondent Nos.1 to 4; and learned Assistant Government Pleader for Forest appearing on behalf of the respondent No.5; and perused the material on record.

2. This writ petition is filed by the petitioner seeking the following relief:

“…..to issue a writ of mandamus, declaring the action of respondent No.2 in proceeding with final hearing and final orders without considering and passing orders on the petitioners’ Memo dt.04.04.2026 filed for furnishing of documents and for counters of respondent Nos.3 & 5, in not granting reasonable opportunity to the petitioners to reply to respondent No.4’s counter affidavit and submit final arguments in Case No.D/2156/2021 regarding the lands in Survey No.168/A (Ac.675-05 Gts) and Survey No.168/AA (Ac.225-01 Gts) of Malachindtalapally Village, Kollapur Mandal, Nagarkurnool District as illegal, arbitrary, unconstitutional, violative of the principles of natural justice and unsustainable, and consequently to direct respondent No.2 to consider and pass appropriate orders regarding the petitioners’ Memo dt.04.04.2026, before proceeding with final arguments and orders in the said case, and to pass such other order/s as this Hon’ble Court may deem fit and in the interest of justice.”

3. The petitioners claim to be the owners and possessors of Acs.900- 06 guntas in Survey Nos.168/A and 168/AA of Malachintalapally Village, Kollapur Mandal, Nagarkurnool District, originally held by their father, late Sri Raja S.V. Jagannadha Rao. During re-survey, the land was erroneously classified as forest land. The said error was rectified by the District Collector’s order dated 25.06.1966, followed by issuance of supplementary Sethwar by recording the name of the petitioners’ father as pattadar. The Commissioner of Survey, Settlement and Land Records, by the order dated 05.12.1981 under Section 166-B , confirmed the petitioners’ title. The petitioners’ title was further confirmed in O.S. No.7 of 1984 dated 25.03.1985. The High Court and the Hon’ble Supreme Court upheld the same, and the matter attained finality. Pursuant thereto, mutation was effected in favour of the petitioners. However, the Tahsildar, Kollapur, without notice, deleted the petitioners’ names and entered the Forest Department in the revenue records. The Revenue Divisional Officer, by the order dated 18.02.2020, set aside the said action and directed restoration of the petitioners’ names. Subsequently, respondent No.2 initiated suo-motu revision in Case No.D/2156/2021 under Section 166-B of the Land Revenue Act, 1317 Fasli. Respondent No.2 failed to furnish documents and did not ensure filing of counter-affidavits by respondent Nos.3 and 5. The petitioners’ filed memo dated 04.04.2026 before the respondent No.2 seeking to furnish documents and to afford an opportunity was not considered. Despite the same, the respondent No.2 is proceeding to pass final orders without granting reasonable opportunity to reply or advance arguments by the petitioners. Hence, the writ petition.

4. Learned Assistant Government Pleader furnished written instructions dated 15.04.2026 and submitted that the subject land parcel claimed by the petitioner is situated within a protected forest tract of critical ecological importance. Geographically, the area is immediately adjacent to the Amrabad Tiger Reserve and falls squarely within its proposed Eco-Sensitive Zone (ESZ) and proposed Tiger corridor. Official wildlife tracking records confirm active Leopard, Slothbear movement. Past records also confirm that there is Tiger movement and the presence of crucial migratory corridor across this land. The terrains possess a highly sensitive and fragile soil ecology that sustains a rich biodiversity. It serves as a vital habitat for key protected wildlife including Leopards, Spotted Deer, and wi