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Patna High Court

Uma DeviversusThe State of Bihar

Decided
Disposal
DISPOSED

Holding

The petition is disposed of, with liberty granted to the petitioner to approach the revenue authorities for redress.

Summary

Uma Devi, a long‑time resident of a parcel of land in Begusarai, filed a writ petition seeking a declaration of title and directions to have her name entered in the Jamabandi register, relying on a Gazette notification dated 11‑Nov‑2014 that declared tenancy rights after 30 years of possession. She also requested the authorities to act on her application dated 27‑Jan‑2026 and issue a revenue receipt. The petitioners' counsel argued that the petitioner should be allowed to approach the Collector and other revenue officials for redress. The State counsel raised no objection. The Court granted the petitioner liberty to approach the concerned authorities and disposed of the writ petition without granting any substantive relief, indicating that the matter should be concluded by the end of the year if the petition is re‑filed within eight weeks.

Issues considered

  • What is the appropriate remedy for a tenant seeking declaration of title and registration of land under the Gazette notification on tenancy rights?
  • Whether the High Court can dispose of the writ petition by merely granting liberty to approach revenue authorities without ordering specific relief.

Subjects

  • title declaration
  • tenancy rights
  • land reforms
  • Jamabandi
  • writ petition
  • Bihar

Judgment

                     IN THE HIGH COURT OF JUDICATURE AT PATNA
                                Civil Writ Jurisdiction Case No.3019 of 2026
                 ======================================================
                 Uma Devi Wife of Vijay Sahni, Resident of Ward No. - 10, Village and P.O.-
                 Mozafra, P.S.- Beerpur, District- Begusarai.

                                                                             ... ... Petitioner/s
                                                   Versus
           1.    The State of Bihar through the Chief Secretary, Govt. of Bihar, Patna.
           2.    The Chief Secretary, Revenue and Land Reforms Department, Govt. of
                 Bihar, Patna.
           3.    The District Magistrate, Begusarai.
           4.    The Addl. Deputy Collector, Begusarai.
           5.    The Sub Divisional Officer, Begusarai.
           6.    The Deputy Collector of Land Reforms, Begusarai.
           7.    The Circle Officer, Beerpur, Begusarai.
           8.    The Circle Inspector, Beerpur, Begusarai.
           9.    The Revenue Halka Karamchari, Mozafra, Beerpur, Begusarai.

                                                           ... ... Respondent/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s   :       Mr. Kumar Praveen, Advocate
                 For the Respondent/s   :       Mr. Divya Verma, AC to AAG-3
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE RAJIV ROY
                                       ORAL ORDER

3   20-04-2026                 Heard Mr. Kumar Praveen, learned counsel for the

                   petitioner and the State.

                               2. The present petition has been preferred for the

                   following relief(s):

                                              “A) For the issuance of appropriate

                                  writ/writs, order/orders, direction/directions to the

                                  concerned Respondent authorities to immediately

                                  take action on the application dated 27.01.2026

                                  (Annexure-2) filed by the petitioner before the
Patna High Court CWJC No.3019 of 2026(3) dt.20-04-2026
                                            2/3




                          concerned respondents for declaration of Title on

                          the land upon which petitioner and her family

                          members are residing for last several decades in

                          the light of Gazette publication dated 11.11.2014

                          (Annexure-1) issued by the Revenue and Land

                          Reforms Department of the state govt. regarding

                          declaration of title of the tenants on the basis of

                          possession over the land for more than 30 years.

                                      B) For direction to the respondent

                          concerned to decide the issue raised by the

                          petitioner expeditiously and after completing the

                          all formalities and to enter his name in Jamabandi

                          Register and to issue revenue receipt of the said

                          land within a reasonable period.

                                      C) For any other relief/reliefs to which

                          the petitioner is found entitled under the facts and

                          circumstances of the present case.”

                      3. After some argument, learned counsel for the

          petitioner submits that it will suffice if he is allowed to approach

          the     respondent        authorities          including   the   Collector,

          Begusarai/Circle Officer, Beerpur, Begusarai for the redressal of

          the grievance.
          Patna High Court CWJC No.3019 of 2026(3) dt.20-04-2026
                                                      3/3




                                4. Learned State counsel has no objection.

                                5. In that background, granting liberty to the petitioner

                    to take appropriate steps, as recorded above, the writ petition

                    stands disposed of.

                                6. If the petition is preferred in next eight weeks, it is

                    expected that the Collector, Begusarai/Circle Officer, Beerpur,

                    Begusarai shall be taking the matter to its logical conclusion

                    preferably by the end of this year.



                                                  (Rajiv Roy, J)
Adnan/-

U


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