Patna High Court

Amrendra KumarversusThe State of Bihar

Decided: 19 January 2026
Disposal: DISPOSED
Bench: ANIL KUMAR SINHA

Holding

The Circle Officer, Dhanarua must decide the petitioner's mutation application within three months of receipt of the court's order.

Summary

The petitioner, Amrendra Kumar, purchased a 3.125 decimal plot of land in Mauza‑Abdullahpur, Patna and applied for mutation of the title in his name on 25‑09‑2025. Despite filing a representation on 11‑11‑2025, the mutation order remained pending. The petitioner filed a writ petition seeking a directive to the Circle Officer, Dhanarua, to decide the mutation application. The State argued that the Circle Officer should act in accordance with law. The High Court, after hearing, directed the Circle Officer to pass a decision on the mutation application within three months of receipt of the order and disposed of the writ petition. The order essentially compels the administrative authority to act on the pending mutation request.

Issues considered

Whether the Circle Officer, Dhanarua, is required to decide the petitioner's application for mutation of land title in accordance with law

Subjects

mutation of land records
property law
writ jurisdiction
administrative law
land reforms

Judgment

                     IN THE HIGH COURT OF JUDICATURE AT PATNA
                                  Civil Writ Jurisdiction Case No.221 of 2026
                 ======================================================
                 Amrendra Kumar S/o Suresh Prasad, Resident of Pabhera, P.O.- Pabhera,
                 Distt.- Patna, Bihar - 804451.

                                                                       ... ... Petitioner/s
                                                   Versus
           1.    The State of Bihar through the Principal Secretary, Revenue and Land
                 Reforms Department, Bihar, Patna.
           2.    The Principal Secretary, Revenue and Land Reforms Department, Govt. of
                 Bihar, Patna.
           3.    The Collector, Distt.- Patna.
           4.    The Additional Collector, Distt.- Patna.
           5.    The Deputy Collector, Land Reforms, Distt.- Patna.
           6.    The Circle Officer, Dhanarua, Distt.- Patna.

                                                           ... ... Respondent/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s   :        Mr. Kaustubh Prakash
                 For the Respondent/s   :        Mr. Government Advocate (11)
                                                 Mr. Prabhat Kumar, AC to GA 11
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE ANIL KUMAR SINHA
                                       ORAL ORDER

2   19-01-2026        1. Heard the parties.

                      2. Petitioner purchased a piece of land at Mauza-

                   Abdullahpur, Pabhera, Thana- Dhanarua bearing Khata No. 55,

                   Survey Plot No. 2444 having an area of 3.125 decimal from one

                   Sugreev Prasad through registered sale deed dated 28.06.2025

                   having deed no. 4453.

                      3. Learned counsel for the petitioner submits that petitioner

                   filed an application on 25.09.2025 bearing no. TEMP / 4951 /

                   2025-26 before the Circle Officer, Dhanarua, District – Patna

                   for mutation of his name pertaining to the subject land.
           Patna High Court CWJC No.221 of 2026(2) dt.19-01-2026
                                                       2/2




                     Thereafter, the petitioner filed a representation before the

                     respondent no. 6 -Circle Officer, Dhanarua on 11.11.2025 but

                     the same is still pending and mutation order has not been passed

                     in favour of the petitioner.

                        4. Learned counsel for the State submits that respondent no.

                     6- Circle Officer, Dhanarua may be directed to take decision in

                     accordance with law on the application for mutation submitted

                     by the petitioner.

                        5. Considering the nature of prayer made in the writ

                     application, the respondent no. 6- Circle Officer, Dhanarua,

                     District- Patna is directed to take decision upon the application

                     filed by the petitioner for mutation in accordance with law

                     within a period of three months from the date of receipt /

                     production of a copy of this order.

                        6. With the aforesaid observation and direction, this

                     application is disposed of.



                                              (Anil Kumar Sinha, J)
praful/-

U

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