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Patna High Court

Vishal Kumar SinghversusThe State of Bihar

Decided
Disposal
DISPOSED

Holding

The Court held that the petitioner must first file a fresh representation before the District Magistrate, and therefore the writ application was disposed.

Summary

Vishal Kumar Singh filed a public‑interest litigation seeking correction of the Jamabandi register for Thana Mauza No. 155 and enforcement of an order dated 01‑02‑2016 of the Bihar Chakbandi Directorate that cancelled an earlier chakbandi order. The reliefs prayed for included a mandamus directing revenue authorities to amend land‑record entries, issue receipts as per the corrected records, and to implement the director’s order. The Patna High Court examined whether it could directly compel the authorities without the petitioner first approaching the revenue department. The Court held that the petitioner must first make a fresh representation before the District Magistrate (Respondent No. 3), who must consider it with an opportunity of hearing. Accordingly, the writ application was disposed and any pending applications were also dismissed.

Issues considered

  • Whether the High Court can issue a mandamus directing correction of Jamabandi records without the petitioner first filing a representation before the revenue authority.
  • Whether the order dated 01‑02‑2016 of the Bihar Chakbandi Directorate must be implemented by the revenue officials in the absence of a fresh representation.

Subjects

  • Public Interest Litigation
  • Jamabandi
  • Land Records
  • Mandamus
  • Revenue Law
  • Bihar Chakbandi Directorate
  • Revision Case
  • District Magistrate

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                               Civil Writ Jurisdiction Case No.20699 of 2025
                 ======================================================
                 Vishal Kumar Singh S/O. Sant Kumar Singh R/o Village Nekra, Post-
                 Muradabad, P..S.- Agrer, District- Rohtas at Sasaram.

                                                                              ... ... Petitioner/s
                                                         Versus

           1.    The State of Bihar through Chief Secretary Govt. of Bihar, Patna.
           2.    Additional Chief Secretary Revenue and Land Reforms Department Govt. of
                 Bihar Patna.
           3.    District Magistrate, Rohtas, Sasaram
           4.    A.D.M. Rohtas (Bihar)
           5.    D.C.L.R. Sasaram, Rohtas
           6.    Circle Officer Sasaram Rohtas

                                                           ... ... Respondent/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s   :         Mr. Pankaj Kumar Choubey, Advocate
                 For the State          :         Mr. Md. Fazle Karim, AC to SC-1
                 ======================================================
                 CORAM: HONOURABLE THE ACTING CHIEF JUSTICE
                         and
                         HONOURABLE MR. JUSTICE RAJESH KUMAR VERMA
                                       ORAL ORDER

                 (Per: HONOURABLE THE ACTING CHIEF JUSTICE)

2   06-01-2026                     The present writ application has been filed in the

                   form of a Public Interest Litigation (PIL) for the following

                   reliefs:-

                                                         “i. For a direction of correction of
                                            Jamabandi Registar as per Survey records in Thana
                                            Mauza No.- 155 in revision case No. 234 of 2013
                                            and commanding the Respondent authorities to
                                            ensure compliance of the order dated 01-02-2016
                                            (memo no.- 11/Chak) passed by the director Bihar
                                            Chakbandi Directorate Patna in revision case No.-
                                            234/2013 whereby earlier Chabandi order was
                                            cancelled.
Patna High Court CWJC No.20699 of 2025(2) dt.06-01-2026
                                           2/3




                                              ii. For a direction to the Circle Officer
                                  Sasaram and concerned revenue authorities to make
                                  necessary correction in Jamabandi Register/Land
                                  record (Survey Khata, Plot, Area, Possession details
                                  etc.)
                                              iii.         Issue       an        appropriate
                                  Writ/order/direction for quashing the action of the
                                  concerned authorities whereby the order dated 01-
                                  02-2016 (Memo No. 11/Chak) passed by the
                                  Director, Bihar Chakbandi Directorate, Patna in
                                  Revision Case No.-234/2013 cancelling the earlier
                                  chakbandi order, no. consequential steps have been
                                  taken for implementation of the said order.
                                              iv. Direct the Respondent Authorities to
                                  forthwith implement and give effect to the order
                                  passed    by       the   Director,   Bihar     Chakbandi
                                  Directorate, Patna dated 01-02-2016 (Memo No.
                                  11/chak) and take all consequential steps as
                                  required under law.
                                              v.      Issue     a   writ    of   mandamus
                                  commanding         the      respondent    Authorities   to
                                  correct/rectify the Jamabandi records and revenue
                                  entries strictly in accordance with the order dated
                                  01-02-2016 and ensure that receipts are issued as
                                  per the corrected Jamabandi records in mauza
                                  Thana No. 155.”
                      2. Considering the nature of relief sought, the

          petitioner is directed to file a fresh representation before

          Respondent No. 3. If any such representation is being filed, the

          Respondent No. 3 shall consider the same and pass an

          appropriate order in accordance with law, after giving adequate

          opportunity of hearing to all the stake holders.
           Patna High Court CWJC No.20699 of 2025(2) dt.06-01-2026
                                                      3/3




                                 3. With the aforesaid observation, the writ application

                     stands disposed of.

                                 4. Pending application(s), if any, shall also stand

                     disposed of.



                                              (Sudhir Singh, ACJ)


                                            (Rajesh Kumar Verma, J)
Sachin/-

U


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