The Madhya Pradesh High Court at Jabalpur has set aside orders passed by the Collector, Satna, and the Commissioner, Rewa, that had declared a disputed piece of land as government property. Justice Himanshu Joshi, delivering the judgment on September 25, 2025, observed that the authorities acted beyond their jurisdiction and failed to conduct a proper inquiry before stripping the petitioners of their land rights.
Background
The case arose from a long-standing land dispute in Chitrakoot’s Mazgawan area, Satna district. Petitioners Ramesh Singh and others purchased the property from the original allottees-respondents No.5 and 6-through a registered sale deed in 2004. These sellers had been declared Bhoomiswamis (landowners) back in 1988, following an allotment made in 1978.
However, years later, in 2016, a private individual (respondent No.4), who the court noted had “no nexus” with the land, filed a complaint before the Collector. The Collector, acting suo motu, held that the land belonged to the government. The Commissioner, Rewa Division, upheld this decision in 2022, prompting the present petition under Article 227 of the Constitution.
The petitioners argued that the complaint was malicious and that the complainant was a “habitual blackmailer” who had earlier filed a false civil suit against them-one that had been withdrawn with costs of ₹15,000 imposed on him.
Court’s Observations
Justice Joshi examined the case records and noted that the Collector had taken suo motu action in 2017-over a decade after the land sale and far beyond the 180-day period allowed for such revisions under Section 50 of the Madhya Pradesh Land Revenue Code (MPLRC).
Referring to a Full Bench decision in Ranveer Singh vs State of M.P. (2010), the bench reiterated that “suo motu powers must be exercised within 180 days from the date of knowledge of illegality.” Acting after 13 years, therefore, was legally untenable.
The Court also criticized the haste with which the Collector acted without waiting for a fresh report from the Sub-Divisional Officer. “The Collector has failed to conduct a full-fledged enquiry before passing the order under challenge,” Justice Joshi remarked.
In unusually sharp language, the Court observed, “This case is a classic example of the failure of State machinery. Suddenly, after two decades, upon a complaint by someone who might have personal grudge, the authority woke up from deep sleep.”
He added that the petitioners appeared to be bona fide purchasers, and their Bhoomiswami status-a substantive ownership right-could not be “snatched away on the basis of half-baked investigation.”
Decision
Finding both the Collector’s and Commissioner’s orders legally unsustainable, the High Court quashed them, restoring ownership to the petitioners.
“The orders dated 03.03.2020 and 21.10.2022 are hereby set aside,” the Court concluded. “The petition stands allowed.”
With that, the High Court reaffirmed a fundamental principle-land rights, once duly conferred and unchallenged for decades, cannot be undone by administrative whims or delayed government action.
Case: Ramesh Singh & Others vs. State of Madhya Pradesh & Others
Case Type & No.: Miscellaneous Petition No. 5747 of 2022
Petitioners: Ramesh Singh and others (bona fide land purchasers)
Respondents: State of Madhya Pradesh, Collector Satna, Commissioner Rewa, and others
Date of Judgment: 25 September 2025
