The High Court of Madhya Pradesh has directed revenue authorities to urgently decide a long-pending land ceiling dispute involving the heirs of Late Shahjirao Angre, observing that prolonged pendency defeats the purpose of remand proceedings.
Justice Milind Ramesh Phadke passed the order on May 6, 2026, while hearing a writ petition filed by Smt. Jyotsana Raja Angre and others.
Background of the Case
The dispute arose from proceedings under the Madhya Pradesh Ceiling on Agricultural Holdings Act, 1960. The petitioners challenged a 2012 order of the Board of Revenue which had set aside an earlier decision of the Settlement Commissioner and remanded the matter for fresh adjudication.
According to the petitioners, the Settlement Commissioner had earlier concluded that most of the disputed land was non-agricultural and non-cultivable in nature, while the remaining agricultural land was within the legal ceiling limit. Based on those findings, the ceiling proceedings were dropped in 2010.
However, the Board of Revenue reopened the matter in 2012 and directed the competent authority to complete fresh proceedings within four months. The petitioners told the Court that even after several years, no final decision had been taken.
The Court noted that the remand order was passed nearly 14 years ago with a specific timeline for completion, yet the proceedings were still pending.
“The pendency of such proceedings for an unduly prolonged period defeats the very purpose of remand and causes avoidable hardship to the parties concerned,” the bench observed.
The State government also informed the Court that it had no objection if directions were issued for early disposal of the matter.
Without examining the merits of the land dispute, the High Court directed the Settlement Commissioner to immediately take up the remanded proceedings and decide them in accordance with law after hearing all parties.
The Court ordered that the matter should preferably be decided within two weeks from the receipt of the certified copy of the order. It also clarified that all issues remain open for independent consideration by the competent authority.
Case Details
Case Title: Smt. Jyotsana Raja Angre & Others v. State of Madhya Pradesh & Others
Case Number: Writ Petition No. 15776 of 2026
Judge: Justice Milind Ramesh Phadke
Decision Date: May 6, 2026
