The Chhattisgarh High Court has ruled that a Tehsildar cannot compel a landholder to produce a Rin Pustika (land record booklet) merely because a private individual requests it. Holding that such a direction has no backing under the Chhattisgarh Land Revenue Code, the Court set aside both the Tehsildar's order and the appellate order passed by the Additional Collector.
Background of the Case
The petition was filed by Deepak and another challenging an order dated 30 May 2022, through which the Additional Collector, Raigarh, upheld an earlier order of the Tehsildar dated 17 March 2021. The Tehsildar had directed the petitioners to produce their Rin Pustika after a private respondent moved an application seeking its production.
The petitioners argued that the revenue authority had no legal power to compel them to submit documents solely on the request of a private party.
Court's Observations
Justice Amitendra Kishore Prasad noted that the parties had already been engaged in multiple disputes before civil and revenue courts, with even proceedings before the Supreme Court. However, the Court emphasized that these circumstances did not expand the statutory powers of the Tehsildar.
The bench observed,
"The Tehsildar has no authority or power to compel the petitioners to produce the documents at the instance of a private respondent."
Instead, if a party chooses not to produce relevant documents during a valid proceeding, the authority may only draw an adverse inference where the law permits.
The Court further found that no proceedings were pending before the Tehsildar when the private application was filed. It clarified that an order directing production of documents could be legally justified only if such documents were required for deciding an ongoing case before the authority.
Decision
Holding that the Tehsildar acted beyond the powers conferred by the Chhattisgarh Land Revenue Code, the High Court quashed the order dated 17 March 2021 passed by the Tehsildar as well as the order dated 30 May 2022 passed by the Additional Collector affirming it.
The writ petition was accordingly disposed of.
Case Details
Case Title: Deepak & Another v. State of Chhattisgarh & Others
Case Number: WPC No. 2932 of 2022
Judge: Justice Amitendra Kishore Prasad
Decision Date: 09 July 2026
