The Madhya Pradesh High Court has dismissed a Public Interest Litigation (PIL) seeking a fresh inquiry into the ownership and revenue records of 4.40 acres of land in Dindori, observing that the petitioner failed to establish any prima facie case showing that the disputed parcels were presently recorded as Government Charnoi land.
A Division Bench comprising Chief Justice Alpesh Y. Kogje and Justice Deepak Khot passed the order on September 19, 2026, in Writ Petition No. 21055 of 2021.
Background of the Case
The petition concerned three parcels bearing Khasra Nos. 72/1-Kha, 72/1-Ga and 72/1-Gha, measuring 1.70 acres, 2.30 acres and 0.40 acres respectively, situated in Village Subkhar Maal, Dindori. The petitioner, describing himself as a local journalist and public-spirited citizen, sought an inquiry into the ownership and revenue entries of the land. He relied on the Misal Bandobast of 1929–30 and Adhikar Abhilekh of 1954–55, claiming that the land had originally been recorded as government grazing land (Charnoi).
The petitioner alleged that the revenue entries were subsequently manipulated and that the disputed land was wrongly mutated in private names. The State disputed these allegations and submitted that although the larger Khasra No. 72/1 was recorded as grazing/waste land in the 1929–30 records, by 1954–55 only Khasra No. 72/1-Ka, measuring 18.44 acres, remained recorded as grazing land. The three disputed portions, totalling 4.40 acres, were recorded in the names of different agriculturists as Bhumiswami.
The records further showed a long chain of transactions involving the disputed parcels. Registered sale deeds were executed in 1965, followed by mutation in 1966 and subsequent partition proceedings. In 2006, a 0.40-acre portion was gifted to Rama Devi Shiksha Evam Seva Samiti, and the land was later diverted for educational purposes under Section 172 of the Madhya Pradesh Land Revenue Code by an order dated June 27, 2007. The State also relied on subsequent revenue inquiries to contend that the disputed portions had not been recorded as government grazing land from 1954–55 onwards.
The Bench noted that the disputed parcels had remained recorded in private names for several decades. The records showed registered sale deeds from 1965, subsequent mutation and partition proceedings, and a later transfer of part of the land in 2006. The Court found no material showing that these transactions were forged or brought about through fraud or collusion.
The Court observed:
“A PIL cannot be permitted to unsettle rights flowing from registered transactions which have remained operative and acted upon for more than five decades, particularly when no prima facie fraud, illegality or continuing public injury has been established.”
The Bench further held that allowing the requested investigation would effectively require the Court to reopen the validity of long-standing transactions and competing claims of title, which was impermissible in the present PIL proceedings.
The Court also referred to Supreme Court decisions emphasizing that PIL jurisdiction must be exercised with care, particularly where the proceedings could require the Court to examine long-standing property rights or competing claims of title.
The High Court concluded that the petitioner had failed to establish that the land was presently recorded as Government Charnoi land or that the private parties had illegally acquired rights over it. It therefore found no basis for directing any fresh revenue, departmental or criminal inquiry.
The PIL was accordingly dismissed, while pending interlocutory applications were also disposed of. The Court made no order as to costs.
Case Title: Anil Patel v. The State of Madhya Pradesh and Others
Case Number: Writ Petition No. 21055 of 2021
