The Supreme Court on Friday quietly but firmly settled a dispute that had been simmering in rural Barmer for years - whether two newly created revenue villages in Rajasthan were named in violation of the State’s own policy. Sitting in Court, the bench made it clear that government policies on village naming are not just ornamental guidelines. When the dust settled, the top court restored an earlier High Court order that had struck down the creation of the villages Amargarh and Sagatsar.
The case arose from village Sohda in Barmer district, but its implications travel much further, touching on how far the State can bend its own rules.
Background
The controversy traces back to December 2020, when the Rajasthan government issued a notification creating several new revenue villages, including Amargarh and Sagatsar. These villages were carved out of Meghwalon Ki Dhani, following a proposal from the local Gram Panchayat. The Tehsildar had certified that everything was in order - boundaries verified, no disputes, and no link to any individual or community.
Later, affidavits surfaced showing that land for these villages was donated by two locals, Amarram and Sagat Singh. Years passed. Then in 2025, during a larger exercise of reorganising panchayats, objections were raised by villagers claiming that the names “Amargarh” and “Sagatsar” were clearly derived from individual names, which State policy forbids.
A Single Judge of the Rajasthan High Court agreed and quashed the notification for these two villages, allowing the State to rename them lawfully. However, a Division Bench overturned that order, prompting the matter to reach the Supreme Court.
Court’s Observations
The Supreme Court examined Section 16 of the Rajasthan Land Revenue Act, which gives the State power to create or alter villages. But the bench did not stop there. It focused sharply on a 2009 government circular that lays down naming rules, especially Clause 4, which bars village names based on any person, religion, caste, or sub-caste.
“The circular is a policy decision, and such policies bind the government,” the bench observed, adding that the objective was to maintain communal harmony. The judges were unpersuaded by arguments that the circular was merely advisory or that settled matters should not be reopened.
On facts, the bench noted that the names Amargarh and Sagatsar were admittedly drawn from Amarram and Sagat Singh. “The State cannot be permitted to act in contravention of the policy framed by it,” the court said, holding that such action would be arbitrary and violate the Constitution’s equality guarantee.
The bench also faulted the Division Bench of the High Court for focusing only on whether earlier rulings applied retrospectively, instead of examining the legality of the naming itself.
Decision
In the end, the Supreme Court quashed the Rajasthan High Court Division Bench judgment dated August 5, 2025, and restored the Single Judge’s order striking down the 2020 notification insofar as it created the revenue villages Amargarh and Sagatsar. The appeal was allowed, with no order on costs, effectively reviving the direction that the villages may be renamed in accordance with law.
Case Title: Bhika Ram & Anr. vs State of Rajasthan & Ors.
Case No.: Civil Appeal arising out of SLP (C) No. 27965 of 2025
Case Type: Civil Appeal (Land Revenue / Village Naming Dispute)
Decision Date: December 19, 2025