In a detailed ruling that revisits land reforms from the 1950s, the Supreme Court of India has set aside a West Bengal government-backed review that allowed a private company to reclaim hundreds of acres of agricultural land decades after it was vested in the State.
The court held that a revenue officer had no legal authority to reopen a concluded land vesting decision from 1971, even if the review was directed by the State government itself.
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Background of the Case
The dispute traces back to land acquired by Jai Hind Pvt. Ltd., a company incorporated in 1946. Before January 1, 1952, the firm had purchased over 200 acres of agricultural land in Murshidabad district.
When the West Bengal Estates Acquisition Act, 1953 came into force, estates held by intermediaries were vested in the State, subject to limited exceptions. One such exception allowed companies engaged exclusively in farming to retain land if they could prove this status as of January 1, 1952.
In 1971, a revenue officer examined Jai Hind’s claim under this provision and rejected it, finding that the company failed to prove it was engaged solely in agricultural activity. As a result, more than 200 acres were vested in the State.
That order survived multiple legal challenges. Writ petitions were dismissed, restoration attempts failed, and by 2002, the 1971 vesting decision had attained finality.
The 2008 Turnaround
Years later, while another land ceiling dispute was pending, the company approached the State government seeking an “amicable settlement.” In February 2008, the Principal Secretary of the Land and Land Reforms Department issued an order directing a review of the 1971 proceedings.
Acting on this, the local Block Land and Land Reforms Officer reviewed the old case and, in May 2008, reversed the earlier decision. Jai Hind was allowed to retain about 211 acres of land, citing its proposed agro-based industrial project and employment potential.
The State later challenged this reversal, arguing that the review itself was illegal.
Court’s Observations
The Supreme Court was unequivocal on the limits of administrative power.
“The power of review is not an inherent power,” the bench observed, adding that such authority must be clearly granted by statute. Revenue officers, the court said, are executive officials exercising limited quasi-judicial functions and cannot reopen settled decisions unless the law expressly allows it.
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The judges rejected the argument that a general notification giving revenue officers civil court powers included the power of review. “A blanket conferment of powers cannot be read to include review of final orders,” the court noted.
Importantly, the bench pointed out that the 1971 decision had already been examined by courts and allowed to stand. “Finality cannot be sacrificed on the altar of administrative convenience,” the court remarked.
On Exclusive Farming Claim
Even on merits, the court found no justification for reopening the case. It noted that Jai Hind had been given multiple opportunities in 1971 to prove it was engaged exclusively in farming but failed to do so.
“The mere ownership of agricultural land or payment of agricultural tax does not establish exclusive engagement in farming,” the bench said, recalling the findings of the original revenue officer.
The court also highlighted that documents relied upon in the 2008 review were never produced during the original proceedings.
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The Decision
Allowing the appeal filed by the State of West Bengal, the Supreme Court set aside the Calcutta High Court’s 2012 judgment that had upheld the review.
The court declared the 2008 government order and the subsequent review by the revenue officer as void and without jurisdiction. As a result, the original 1971 vesting order stands restored, and the land in question continues to vest with the State.
Case Title: State of West Bengal & Ors. vs Jai Hind Pvt. Ltd.
Case No.: Civil Appeal No. 7407 of 2012
Decision Date: 6 February 2026
