Patna High Court

Jay Prakash SinghversusThe State of Bihar

Decided: 18 February 2026
Disposal: DISPOSED
Bench: NAWNEET KUMAR PANDEY

Holding

The Court modified the earlier order to allow the Circle Officer to requisition police force if a threat to law and order is felt, thereby disposing of the petitioner's application.

Summary

The petitioner, Jay Prakash Singh, sought a court order directing the Circle Officer of Barh to measure his land within six weeks. The Patna High Court had earlier, on 22 January 2025, ordered the Circle Officer to dispose of the application in accordance with law. The petitioner appealed, arguing that the earlier order did not provide adequate protection against potential law and order disturbances during the measurement process. The Court modified the earlier order, permitting the Circle Officer to requisition police assistance from the Superintendent of Police if a threat to law and order is perceived. With this modification, the Court held that the application was disposed of.

Issues considered

What authority does a Circle Officer have to requisition police assistance when executing land measurement orders?
Whether the original order directing measurement within six weeks is sufficient without provisions for maintaining law and order.

Subjects

land measurement
revenue law
administrative order
law and order
police requisition
high court judgment

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                                         CIVIL REVIEW No.64 of 2025
                                                       In
                                  Civil Writ Jurisdiction Case No.463 of 2025
                 ======================================================
                 Jay Prakash Singh Late Ram Sanehi Singh Resident of Village- Ekdanga,
                 P.S.- Belchi, District- Patna.

                                                                             ... ... Petitioner/s
                                                    Versus

           1.    The State of Bihar thorough the Principal Secretary, Revenue and Land
                 Reforms Department, Government, of Bihar, Patna.
           2.    The District Magistrate, Patna.
           3.    The Sub-Divisional Officer, Barh, District-Patna.
           4.    The Circle Officer, Barh Anchal, District-Patna.

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s   :      Mr. Prem Kumar
                 For the State          :      Mr. Additional Advocate General 12
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE NAWNEET KUMAR
                 PANDEY
                                       ORAL ORDER

4   18-02-2026                   Vide order dated 22.01.2025 passed in C.W.J.C. No.

                   463 of 2025, this Court directed the Circle Officer, Barh, Patna

                   to dispose of the application filed by the petitioner for

                   measurement of his land preferably within a period of six

                   weeks, in accordance with law.

                                 2. Order dated 22.01.2025 is modified to the extent

                   that in disposing of the application filed by the petitioner, if the

                   Circle Officer, Barh, Patna feels a threat of law and order, he

                   may requisition the police force from the Superintendent of

                   Police, Patna.
             Patna High Court C. REV. No.64 of 2025(4) dt.18-02-2026
                                                          2/2




                                    3. With this observation, this application stands

                       disposed of.


                                             (Nawneet Kumar Pandey, J)

priyanka/-

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